Adams v Rhymney Valley DC [2000] Lloyd’s Rep PN 777
TORT – NEGLIGENCE – STANDARD OF CARE – PROFESSIONAL LANDLORDS
Facts
The defendant was a local authority and a professional landlord who replaced a set of double-glazed windows in their tenant’s accommodation with locks with removeable keys. The defendant had designed the windows themselves. As a result of these locks, the tenant’s children were unable to escape through the windows during a house fire, and died. The tenant sued the defendant in the tort of negligence.
Issue
Establishing negligence involves showing that the defendant breached their duty of care to the claimant. To establish breach, the claimant must establish that the defendant failed to act as a reasonable person would in their position. This is known as the standard of care. This standard is higher in the case of professionals: they must act as a reasonable professional would.
The issue was the standard of care which was required of a professional landlord.
Decision/Outcome
The Court of Appeal held that the defendant was not liable.
The Court held that the defendant had exercised reasonable skill and care, and produced a design which other professionals had also produced and used. They were not negligent simply because they had not consulted the entirety of the profession and assessed the range of contrary views before determining the design.
This principle followed from the principles in the Bolam v Friern Hospital Management Committee and Bolitho v City & Hackney Health Authority cases, which held that a professional will not be in breach of their duty of care if they acted in a manner which was in accordance with practices accepted as proper by a responsible body of other professionals with expertise in that particular area, unless that practice was indefensible or illogical.
Updated 19 March 2026
This article remains broadly accurate as a summary of Adams v Rhymney Valley District Council [2000] Lloyd’s Rep PN 777. The Court of Appeal’s decision and its application of the Bolam/Bolitho standard of care to professional landlords are correctly stated.
The underlying legal principles from Bolam v Friern Hospital Management Committee [1957] 1 WLR 582 and Bolitho v City & Hackney Health Authority [1998] AC 232 remain good law and have not been materially altered by subsequent legislation or case law. The Bolam test continues to apply to professional defendants beyond the clinical context, including, as this case illustrates, professional landlords. There have been no statutory or judicial developments that would undermine the case’s authority or the principles it applies.
Readers should note that the article describes the standard of care for professionals generally. In the specific context of clinical negligence, the Supreme Court’s decision in Montgomery v Lanarkshire Health Board [2015] AC 1430 modified the application of Bolam in relation to the duty to warn patients of risks, though this does not affect the principles as applied in Adams itself.
