offence under s 34 and appealed. On appeal it was held that proof of causation of danger was not needed for a conviction: the question was whether the facts proved could properly be described as endangering the safety of any person conveyed on the railway. The conviction was therefore upheld. Giving the judgment of the court, Widgery J said at p 622: : In relation to occupational health and safety, from the middle of the nineteenth century, regulatory legislation imposed duties on persons, most generally employers, requiring them to conduct their operations to the standards required by the legislation or incur criminal liability. The imposition of duties, enforced through the criminal law, on employers who were, and are,

doi:10.4324/9781843140504-140

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offence under s 34 and appealed. On appeal it was held that proof of causation of danger was not needed for a conviction: the question was whether the facts proved could properly be described as endangering the safety of any person conveyed on the railway. The conviction was therefore upheld. Giving the judgment of the court, Widgery J said at p 622:

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ABSTRACT

Even if these two statutory offences might be committed by persons, such as a lorry or train driver, in the course of their employment, they were not enacted primarily for the regulation of work or the protection of workers.