Court: Queen’s Bench Division
Judgment Date: 7 February 1979
Where Reported: [1980] 1 W.L.R. 823; [1980] 1 All E.R. 7
Legal Issue in Roberts v Ramsbottom
The central legal issue in Roberts v Ramsbottom was whether a motorist, unknowingly suffering from a stroke and impaired consciousness, could be held liable for negligence.
The case examined whether such a driver, who had some awareness of his surroundings yet was impaired, could be considered to have acted in a state of automatism and thereby not responsible for his actions.
The question revolved around the application of objective standards of care in negligence, particularly in situations where the driver’s capacity to control the vehicle is clouded due to a medical condition​​.
Judgment in Roberts v Ramsbottom
The court, in its judgment, held that Ramsbottom was liable for negligence.
The court applied an objective standard of care, requiring drivers, including those impaired or in a state of automatism, to maintain a standard of skill, experience, and care.
The court distinguished between total unconsciousness and impaired consciousness, noting that Ramsbottom had some control over the vehicle despite his impaired state. Consequently, his condition did not amount to legal automatism.
The court ruled that Ramsbottom should have been aware of his unfitness to drive after the initial collision and his continuing to drive despite his disabling symptoms constituted negligence.
Thus, he was held legally liable for the accident and the damages caused​​.
The Reason for the Decision in Roberts v Ramsbottom
The court’s decision was guided by principles concerning the objective standard of care in negligence and the concept of automatism in law.
In negligence cases, the standard of care is an objective one, requiring a driver to act with the skill and care of a competent and experienced driver.
This standard applies irrespective of the driver’s personal condition, including whether they are a learner, infirm, or impaired.
In Roberts v Ramsbottom, Ramsbottom’s actions were evaluated against this objective standard.
Although he was suffering from a stroke, he was not entirely unconscious but rather had impaired consciousness.
The court emphasised that even if a driver is suffering from a brain malfunction leading to impaired consciousness, they are still expected to exercise control over their vehicle to the extent possible.
The court relied on precedents that distinguished between complete automatism, involving total loss of control, and situations where the driver retains some control.
Ramsbottom’s condition was such that he retained some degree of control and awareness of his environment, making deliberate movements to operate the vehicle.
This situation differed from cases of total automatism, where a driver loses all control due to a sudden and overwhelming misfortune.
Since Ramsbottom was not completely incapacitated and continued to drive despite being aware of his unfitness and the initial collision, the court found him negligent.
The court also considered the broader implications of accepting impaired consciousness as a defence in negligence.
Allowing such a defence would set a precedent that could significantly lower the standard of care required of drivers and potentially increase the risk to public safety.
Ultimately, the judgment in Roberts v Ramsbottom was based on the premise that a driver’s partial awareness and ability to control the vehicle, albeit imperfectly, does not absolve them of responsibility for their actions.
The court held that Ramsbottom, despite his medical condition, had a legal duty to cease driving once he became aware of his impaired state and the initial collision​​.
Conclusion
Roberts v Ramsbottom established an important precedent in the application of negligence law to cases involving drivers with medical conditions impairing their ability to drive.
The court’s decision underscored the primacy of an objective standard of care in assessing driver negligence and clarified the limited scope of the automatism defence.
The ruling in Roberts v Ramsbottom highlighted that drivers, regardless of their medical conditions, are expected to uphold a standard of care consistent with a competent and experienced driver, thereby reinforcing the importance of public safety on the roads​​.
