The claimant in this case had been employed by the defendant local authority and had retired in May 2004. His retirement on the grounds of ill health had been agreed in February that year. The claimant’s last working day was on 30 June 2003, at which time he suffered a mental breakdown. The claimant brought a claim for damages resulting from the local authority’s negligence as his employer. The judge found that the local authority’s negligence had caused the claimant’s mental breakdown but that the effect of that negligence was limited to a period of twelve months from the claimant’s last working day. The judge held that the causative effect of any breach of duty ceased at the end of June 2004, being superseded from that point by the effects of the breakdown of the claimant’s marriage and related factors. The judge awarded the claimant £4,891.42 as representing loss of earnings up to 30 June 2004 but not beyond. The claimant appealed.
The appeal was allowed in relation to the judge’s findings insofar as they affected the issue of loss of earnings from 30 June 2004. It was held that in the circumstances, the judge’s process of reasoning was obscure, if not non-existent, and had not condescended on the sort of careful analysis which such an issue required. He seemed not to have asked himself what the position would have been if there had been no breach of duty in 2003 and no work stress related breakdown in June 2003. There had been no finding that the effects of the marital breakdown had been so severe that they would have led to dismissal in their own right. There was also no apparent consideration of the fact that the marital breakdown had taken place at a time when the claimant was vulnerable and suffering from the effects of the work-related breakdown. It was not possible to spell out from the terms of the judgment that the claimant would in any event have lost his job because of mental stress arising from his marriage breakdown, notwithstanding the local authority’s breach of duty in relation to work related stress in 2003. The judge’s approach had not revealed a consideration of the issues or a chain of reasoning sufficient to underpin his finding of the issue of causation.