Corr v IBC - Civil liability and employee suicide

Abstract

The English Court of Appeal decision in Corr v IBC Vehicles Ltd1 held that an employer could be found liable for the suicide of an employee. 2 Sedley and Wilson LJJ (with Ward LJ dissenting) overturned the trial court decision of Baker J. who had held that suicide was not a foreseeable kind of harm for which the employer could be held liable. The majority held that suicide did not have to be foreseeable as a different ‘kind of damage’, it would suffice that the depressive illness which gave rise to the suicide was foreseeable. This was based on the acceptance by the majority that suicide is a type of harm which flows from a depressive illness. The Court also held that suicide did not automatically attract the qualities of a novus actus interveniens so as to break the chain of causation