IN the relationships between worker and employer, the latter has gathered, through the years, a number of duties which are statutorily defined and which he is obliged to honour. If he does not, the worker can sue him for damages. The right of the worker so to sue was not granted by the first Factory Act in 1802, where action was limited to the criminal courts. But, by 1844, Factory Acts had begun to take on their modern form, their provisions including the necessity to fence machinery, and from this time forward the worker was not precluded from seeking damages by civil action.