Young v Bristol Aeroplane [1944]
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Young v Bristol Aeroplane Company Limited [1944] 1 KB 718, decided in the Court of Appeal, established a significant precedent regarding the Court of Appeal's obligation to follow its own decisions. The case was heard by a full bench consisting of Lord Greene MR, Scott, MacKinnon, Luxmoore, Goddard, and du Parcq LJJ. The Court of Appeal ruled that it is generally bound to follow its previous decisions and those of courts of co-ordinate jurisdiction, even when sitting as a full court. The Court identified three exceptions to this rule:
The plaintiff, who had been injured at work and compensated under the Workmen's Compensation Acts, sought damages, alleging that his employer failed to fence a machine in breach of their statutory duty. The defendants argued that the plaintiff's claim was barred because he had already received compensation under the Workmen's Compensation Act, 1925, as per Section 29(1). The commissioner at the Lancaster Assizes ruled in favour of the defendants based on the authority of a previous Court of Appeal decision in Perkins v Hugh Stevenson Sons, Ltd [1940]. The plaintiff appealed, contending that the earlier decisions, particularly Perkins and Selwood v Townley Coal Fireclay Co Ltd [1940], were wrongly decided and inconsistent with the House of Lords decision in Kinneil Cannel and Coking Coal Co v Sneddon [1931].
Lord Greene MR, delivering the judgment of the court, upheld the commissioner's decision, affirming that the plaintiff’s claim was barred since he knowingly accepted compensation as such under the Act. The court determined that the judgments in Perkins and Selwood were consistent with the legal framework of the Workmen's Compensation Act and the principle of finality in law. It dismissed the plaintiff's argument that those decisions were contrary to the House of Lords ruling in Kinneil, explaining that Kinneil involved different facts and was not relevant to the issue of whether compensation acceptance precluded further damages claims.
The Court further reiterated the established principle that it is bound by its own decisions unless the circumstances fall within one of the three outlined exceptions. The court emphasised the importance of maintaining consistency and finality in the law, pointing to multiple past cases where the Court of Appeal had expressed regret at being bound by previous decisions but acknowledged the necessity of abiding by established authority until such decisions were overruled by the House of Lords. The appeal was ultimately dismissed, and the Court confirmed that, under the Workmen's Compensation Act, once compensation was knowingly accepted, further damages claims were precluded.
- Where there are conflicting past decisions of the Court of Appeal, it may choose which to follow;
- If a previous decision cannot stand with a decision of the House of Lords (now the Supreme Court), the Court of Appeal must refuse to follow its own ruling; and
- The Court of Appeal is not bound by its own decision if it was made per incuriam (i.e. through lack of care), for example if it overlooked a relevant statute or rule with statutory effect that would have influenced the outcome.
The plaintiff, who had been injured at work and compensated under the Workmen's Compensation Acts, sought damages, alleging that his employer failed to fence a machine in breach of their statutory duty. The defendants argued that the plaintiff's claim was barred because he had already received compensation under the Workmen's Compensation Act, 1925, as per Section 29(1). The commissioner at the Lancaster Assizes ruled in favour of the defendants based on the authority of a previous Court of Appeal decision in Perkins v Hugh Stevenson Sons, Ltd [1940]. The plaintiff appealed, contending that the earlier decisions, particularly Perkins and Selwood v Townley Coal Fireclay Co Ltd [1940], were wrongly decided and inconsistent with the House of Lords decision in Kinneil Cannel and Coking Coal Co v Sneddon [1931].
Lord Greene MR, delivering the judgment of the court, upheld the commissioner's decision, affirming that the plaintiff’s claim was barred since he knowingly accepted compensation as such under the Act. The court determined that the judgments in Perkins and Selwood were consistent with the legal framework of the Workmen's Compensation Act and the principle of finality in law. It dismissed the plaintiff's argument that those decisions were contrary to the House of Lords ruling in Kinneil, explaining that Kinneil involved different facts and was not relevant to the issue of whether compensation acceptance precluded further damages claims.
The Court further reiterated the established principle that it is bound by its own decisions unless the circumstances fall within one of the three outlined exceptions. The court emphasised the importance of maintaining consistency and finality in the law, pointing to multiple past cases where the Court of Appeal had expressed regret at being bound by previous decisions but acknowledged the necessity of abiding by established authority until such decisions were overruled by the House of Lords. The appeal was ultimately dismissed, and the Court confirmed that, under the Workmen's Compensation Act, once compensation was knowingly accepted, further damages claims were precluded.
