Vaughan v. Taff Vale Railway Co.

Facts

• The defendant railway company was statutorily authorised to operate its railway
• Sparks from properly maintained and operated locomotives ignited a fire on the plaintiff's adjoining land
• There was no additional negligence in the locomotives' operation beyond this inherent spark risk
• The plaintiff sued for the resulting fire damage

Issue

1. Whether a statutorily authorised railway company is liable for fire damage caused by sparks from its properly operating, authorised locomotives.

Held

• The statute authorised operation of the railway, including its locomotives
• The fire resulted from the inevitable, ordinary consequence of properly operating this statutorily authorised activity
• No additional negligence was shown
• The company was not liable; statutory authority provided a complete defence

Ratio Decidendi

Where harm flows as an inevitable, unavoidable consequence of properly conducting a specifically authorised activity, without additional negligence, statutory authority provides a complete defence. This does not extend to harm resulting from the defendant's own avoidable negligence in exercising that authority.