which it turned has ceased to exist. It is therefore rather difficult to find cases which are still recognised as precedents. There have, in fact, been few cases reported for the past 20 or more years. There may be a number of reasons for this, including: litigation has already determined the meaning of the statutory wording; the decline of the heavy industries to which much of the legislation was applicable; and the common law of negligence has so developed that the statutory provisions are no longer relied on in civil courts. Several of the cases referred to in the previous chapter (for example, Bux v Slough Metals Ltd (1974)) included claims for breach of statutory duty as well as claims for negligence, but these cases have not been relied upon in what follows, in order to give a wider selection of cases. There are situations in which the ratio of the case may remain of importance after the statute in question has ceased to apply, because the case discusses principles which transcend the facts and the law before the court at the time the case was heard. This account, though citing old cases, seeks to pinpoint some of the issues which are likely still to be relevant to cases for breach of statutory duty. Therefore, the cases which follow may be classified as follows: (i) those illustrating general principles of statutory interpretation – for example, Carroll v Andrew Barclay & Sons Ltd (1948); (ii) those concerning criteria relevant to current legislation, though decided in relation to earlier legislation – for example, Edwards v National Coal Board (1949); (iii)interpretations of statutes that continue in force – for example, Knowles v Liverpool City Council (1993). (i) Cases illustrating general principles of statutory interpretation Was the defendant in breach of duty to the claimant? BOYLE v KODAK LTD [1969] 2 All ER 439 Lord Reid gave the following speech in the House of Lords, beginning at p 439:

DOI link for which it turned has ceased to exist. It is therefore rather difficult to find cases which are still recognised as precedents. There have, in fact, been few cases reported for the past 20 or more years. There may be a number of reasons for this, including: litigation has already determined the meaning of the statutory wording; the decline of the heavy industries to which much of the legislation was applicable; and the common law of negligence has so developed that the statutory provisions are no longer relied on in civil courts. Several of the cases referred to in the previous chapter (for example, Bux v Slough Metals Ltd (1974)) included claims for breach of statutory duty as well as claims for negligence, but these cases have not been relied upon in what follows, in order to give a wider selection of cases. There are situations in which the ratio of the case may remain of importance after the statute in question has ceased to apply, because the case discusses principles which transcend the facts and the law before the court at the time the case was heard. This account, though citing old cases, seeks to pinpoint some of the issues which are likely still to be relevant to cases for breach of statutory duty. Therefore, the cases which follow may be classified as follows: (i) those illustrating general principles of statutory interpretation – for example, Carroll v Andrew Barclay & Sons Ltd (1948); (ii) those concerning criteria relevant to current legislation, though decided in relation to earlier legislation – for example, Edwards v National Coal Board (1949); (iii)interpretations of statutes that continue in force – for example, Knowles v Liverpool City Council (1993). (i) Cases illustrating general principles of statutory interpretation Was the defendant in breach of duty to the claimant? BOYLE v KODAK LTD [1969] 2 All ER 439 Lord Reid gave the following speech in the House of Lords, beginning at p 439:

which it turned has ceased to exist. It is therefore rather difficult to find cases which are still recognised as precedents. There have, in fact, been few cases reported for the past 20 or more years. There may be a number of reasons for this, including: litigation has already determined the meaning of the statutory wording; the decline of the heavy industries to which much of the legislation was applicable; and the common law of negligence has so developed that the statutory provisions are no longer relied on in civil courts. Several of the cases referred to in the previous chapter (for example, Bux v Slough Metals Ltd (1974)) included claims for breach of statutory duty as well as claims for negligence, but these cases have not been relied upon in what follows, in order to give a wider selection of cases. There are situations in which the ratio of the case may remain of importance after the statute in question has ceased to apply, because the case discusses principles which transcend the facts and the law before the court at the time the case was heard. This account, though citing old cases, seeks to pinpoint some of the issues which are likely still to be relevant to cases for breach of statutory duty. Therefore, the cases which follow may be classified as follows: (i) those illustrating general principles of statutory interpretation – for example, Carroll v Andrew Barclay & Sons Ltd (1948); (ii) those concerning criteria relevant to current legislation, though decided in relation to earlier legislation – for example, Edwards v National Coal Board (1949); (iii)interpretations of statutes that continue in force – for example, Knowles v Liverpool City Council (1993). (i) Cases illustrating general principles of statutory interpretation Was the defendant in breach of duty to the claimant? BOYLE v KODAK LTD [1969] 2 All ER 439 Lord Reid gave the following speech in the House of Lords, beginning at p 439: