Carslogie Steamship Co Ltd v Royal Norwegian Government [1952] AC 292
Law of Tort – Novus Actus Interveniens – Causation – Natural Events – Negligence – Economic Loss
Facts
The complainant’s vessel, Heimgar, was damaged by a collision with the defendant, Carslogie. The defendants admitted negligence and damage and this was not in dispute. The complainant’s had temporary repairs carried out on the vessel and it was certified to sail for New York. On the way, the Heimgar suffered bad damage from stormy weather at sea. The vessel was in need of permanent repairs to fix this damage and this repair work began in New York and would last for 30 days. During that time, the repairs for the collision with the Carslogie were completed.
Issues
The defendant appealed. The issue concerned the original negligent act causing the collision by the defendant and whether this action should be responsible for the further loss that was sustained by stormy water sailing to New York.
Decision/Outcome
It was held that the defendants were only liable and responsible for the loss of profit resulting from the collision, not for further damage sustained by the natural events at sea. The claim for loss during the 10 day period was not awarded. The chain of causation had been broken by the natural event of the storms at sea, which would relieve the defendant from their responsibility for economic loss. Thus, the storm was a novus actus interveniens and the defendants cannot be held liable for further loss that was sustained as a result of a natural event.
Updated 19 March 2026
This case summary describes Carslogie Steamship Co Ltd v Royal Norwegian Government [1952] AC 292, a House of Lords decision. The case remains good law and continues to be cited as authority on causation and novus actus interveniens in tort, particularly in the context of supervening events breaking the chain of causation. No subsequent legislation or case law has overruled or materially altered its standing.
Readers should note, however, that the summary contains a minor but potentially misleading characterisation of the decision. The House of Lords held that the defendants were not liable for the loss of use during the repair period for the collision damage, because the vessel would have been out of service in any event due to the storm damage requiring the 30-day repair. The reasoning was primarily one of causation — the collision damage did not in fact cause any loss of use, since the ship was detained solely by reason of the extensive storm repairs. The article’s framing of the storm as a novus actus interveniens in the traditional sense is a slight oversimplification: the House of Lords’ reasoning focused more on the absence of recoverable loss flowing from the collision than on a classic intervening act breaking the chain. This distinction matters for students applying the case to problem questions. The case otherwise remains an accurate and settled authority in English tort law.
