chapter  20
Pages 8

Intervening causation issues have proven difficult and challenging for judges and scholars alike. In terms of their resolution, these issues appear to defy the application of any single or universal test, prompting one eminent English Law Lord to confess, ‘I find it very difficult to formulate any precise and all-embracing rule.’1 Having said that, Lord Wright proceeded to hypothesise what he considered necessary to sever the causal chain as follows:

It must always be shown that there is something which I will call ultraneous, something unwarrantable, a new cause coming in disturbing the sequence of events, something that can be described as either unreasonable or extraneous or extrinsic. I doubt very much whether the law can be stated more precisely than that.2