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Home » Wheat v E Lacon & Co Ltd

Wheat v E Lacon & Co Ltd

Citation: Wheat v E Lacon & Co Ltd [1966] AC 552; [1966] 1 All ER 582

Court: House of Lords

Area of Law: Tort law – Occupiers’ liability – Duty of care

Wheat v E Lacon & Co Ltd is a significant decision of the House of Lords dealing with the meaning of “occupier” under the Occupiers’ Liability Act 1957. The case examines how responsibility and control over premises determine whether a duty of care is owed to lawful visitors.

The House of Lords was required to consider whether a brewery, which owned a public house but had entrusted day-to-day management to licensees, fell within the statutory definition of an occupier and whether it owed a duty of care to a paying guest who was injured on the premises.

Facts of Wheat v E Lacon & Co Ltd

The defendants were brewers who owned a public house. Rather than managing the premises directly, they had entrusted its operation to licensees, Mr and Mrs Richardson, under a service agreement. Under this arrangement, the licensees were responsible for running the public house and selling drinks in the ground floor area, which was the licensed part of the premises.

The public house also contained a private section. Mr and Mrs Richardson lived on the premises and occupied this private portion. The claimant, Mr Wheat, was staying in this private part as a paying guest with his wife.

One night during the stay, Mr Wheat fell down a staircase located within the private section of the premises. The staircase was poorly lit, and there was no handrail on part of it. During the fall, Mr Wheat fractured his skull and later died as a result of his injuries. Following his death, Mr Wheat’s estate brought a claim against the brewery under the Occupiers’ Liability Act 1957.

Procedural History

At first instance, the trial judge held that the defendants were not liable. The judge reasoned that the defendants could not reasonably have foreseen that Mr Wheat would use the staircase located in the private part of the premises.

The case was then appealed to the Court of Appeal. The Court of Appeal concluded that the defendants were not in occupation of the staircase where the accident occurred.

The matter eventually reached the House of Lords, which was required to determine whether the brewery was an occupier for the purposes of the Occupiers’ Liability Act 1957 and, if so, whether a duty of care was owed in the circumstances.

Issues

The main legal issue in Wheat v E Lacon & Co Ltd before the House of Lords was whether the defendants, as owners of the public house, qualified as “occupiers” under the Occupiers’ Liability Act 1957. This required an assessment of whether they retained sufficient control over the premises despite having licensed the management of the public house to Mr and Mrs Richardson.

A related issue concerned whether more than one occupier could exist at the same time and how responsibility should be allocated when multiple parties had differing degrees of control over different parts of the premises.

Legal Principles Considered

The case required interpretation of the term “occupier” under the Occupiers’ Liability Act 1957. Lord Denning MR delivered the leading speech. He defined an occupier as a person who has sufficient control over the premises such that they ought to realise that any lack of care on their part may cause injury to lawful visitors.

It was also established that occupation is not determined by ownership alone, nor is it limited to a single person. The duty of care may be shared between multiple occupiers, who can be jointly and severally liable where they all fail to exercise reasonable care.

Lord Denning explained that where property is let by demise, the owner remains the occupier of areas not included in the demise, such as common staircases. Where the owner has merely licensed another person to live or operate on the premises, rather than granting exclusive possession, the owner may still be considered an occupier of the entire premises because the right and responsibility to carry out repairs is retained.

It was further recognised that, in some circumstances, contractors working on the premises may also qualify as occupiers.

Wheat v E Lacon & Co Ltd Judgement

The House of Lords held that the defendants retained occupation and control of the premises for the purposes of the Occupiers’ Liability Act 1957. Mr Wheat and his wife were lawful visitors to the public house and were therefore owed a duty of care by the defendants.

The court accepted that occupation could be shared. In this case, the brewery and Mr and Mrs Richardson were all occupiers. However, the extent of their duties differed according to the degree of control each exercised over particular aspects of the premises.

The owners were responsible for ensuring that structural features, such as the handrail, were safe and that the lighting system was properly maintained. However, the House of Lords concluded that the staircase could not reasonably be considered dangerous provided there was adequate lighting.

The absence of light at the relevant time was caused by an unknown person removing the light bulb from the stairway. This act was not attributable to the defendants or to a failure on their part to maintain the premises.

As a result, the House of Lords concluded that the defendants had not failed in their duty of care owed to Mr Wheat as a visitor.

Outcome

Although the defendants were found to be occupiers who owed a duty of care, they were not found to be in breach of that duty. The staircase itself was not inherently dangerous, and the lack of lighting was caused by an intervening act of an unknown stranger.

Accordingly, the appeal was dismissed, and the defendants were not held liable for Mr Wheat’s death. This outcome reaffirmed that the existence of a duty of care does not automatically result in liability; there must also be a failure to meet the required standard of care.

Conclusion

Wheat v E Lacon & Co Ltd remains a leading authority on the definition of “occupier” and the allocation of responsibility under the Occupiers’ Liability Act 1957. The House of Lords emphasised that control is the key factor in determining occupation and that multiple occupiers may owe duties of care to lawful visitors.

However, the case also confirms that liability depends on breach, not merely status, and that occupiers will not be held responsible where danger arises due to unforeseen acts beyond their control.