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Invercargill City Council v. Hamlin (New Zealand)
Invercargill City Council v Hamlin — Privy Council (12 February 1996)
Factual and Procedural Background
The facts, as stated in the opinion, are these. In May 1972 Noel Gordon Hamlin purchased land and contracted for a house to be built at 67 Edinburgh Crescent, Invercargill. A building inspector employed by Invercargill City Council carried out statutory inspections and on 1 June 1972 approved the foundations. Seventeen years later (1989) the plaintiff called in another builder who advised that the foundations were defective. In November 1990 the plaintiff commenced proceedings against the builders and the council claiming the cost of repairs (originally claimed $64,250; damages assessed $53,550 by Williamson J.).
At first instance Williamson J. found the builders in breach of contract but they were effectively insolvent and the plaintiff's recovery depended on a tort claim against the council. The judge found the council's inspector negligent and (for the purposes of the hearing) accepted that the council owed the plaintiff a duty of care; he also found (on the judge's facts) that a reasonably prudent homeowner would not have discovered the cause of the defects until 1989, so the claim in tort was in time.
The council appealed. The Court of Appeal of New Zealand heard the matter and (1994) 3 N.Z.L.R. 513 answered two main issues in favour of the plaintiff: (1) unanimously that the council owed a duty of care; and (2) by majority that the plaintiff's claim was not time-barred (McKay J. dissenting). The case was then brought to the Privy Council on appeal.
Legal Issues Presented
- Whether the Invercargill City Council owed a duty of care to the plaintiff in respect of the building inspector's statutory inspections (i.e., whether a duty of care in tort existed to a subsequent purchaser for defective building work inspected by the council).
- When the cause of action in respect of latent defects in foundations accrues for limitation purposes — at the time of the negligent act or omission / when the physical damage first occurs, or when the defect (and resultant economic loss) becomes known or reasonably discoverable (the "reasonable discoverability" test) — and therefore whether the plaintiff's claim was time-barred.
Arguments of the Parties
Appellant (Invercargill City Council) — as presented in the opinion
- The Court of Appeal should follow the House of Lords decisions in D. & F. Estates Ltd. v. Church Commissioners for England [1989] AC 177 and Murphy v. Brentwood District Council [1991] 1 AC 398, which (it was argued) limited or removed the duty of care for economic loss in such cases; accordingly the council argued it owed no duty of care to the plaintiff.
- On limitation, the council argued the Court of Appeal should follow Pirelli General Cable Works Ltd. v. Oscar Faber & Partners [1983] 2 AC 1 — that a cause of action accrues when the damage to the house came into existence (even if undiscovered) — and that, on that view, the plaintiff issued proceedings too late.
- Miss Bates (for the council) also argued that the Court of Appeal had departed from prior New Zealand authority and had relied improperly (so it was submitted) on Hedley Byrne type principles of assumed responsibility without evidence that the council had assumed responsibility or that the plaintiff had relied on the council; reliance, it was submitted, was not pleaded or proven.
- More broadly, the council urged that the Privy Council should steer New Zealand law into conformity with the then recent House of Lords authority (Murphy) rather than uphold the New Zealand Court of Appeal's departure from English authority.
Respondent / Plaintiff (Hamlin) — as shown in the reasoning reported
- The plaintiff's case (as accepted by the lower courts and reflected in the Court of Appeal judgments) relied on the established New Zealand line of authority (beginning with Bowen and developed in subsequent New Zealand cases) that imposed a duty of care on local authorities in building inspection contexts, founded on concepts of control by the authority and reasonable reliance by purchasers/owners.
- On limitation, the plaintiff's position (and the approach of the New Zealand courts) was that a cause of action for economic loss arising from latent defects accrues when the defect becomes known or reasonably discoverable (when the market value is affected and a reasonable owner would seek expert advice), not at the moment the negligent act occurred.
- Implicitly, the respondent relied on precedent and policy reasons specific to New Zealand (including statutory background and community expectations) to resist adopting the English line of authorities urged by the council.
Table of Precedents Cited
| Precedent | Rule or Principle Cited For (as stated in the opinion) | Application by the Court (as described in the opinion) |
|---|---|---|
| Bowen v. Paramount Builders (Hamilton) Ltd. [1975] 2 N.Z.L.R. 546 | Starting point for New Zealand law on defective foundations and liability; influenced later NZ decisions imposing duty of care. | Described as a convenient starting point; the court treated Bowen as part of the consistent NZ line of authority supporting a duty of care in building defect contexts. |
| Dutton v. Bognor Regis Urban District Council [1972] 1 Q.B. 373 | English authority holding a local authority liable for negligence of a building inspector on similar facts. | Referred to historically as an English influence on early NZ decisions (Bowen); used to show how NZ law initially followed English precedents. |
| Mount Albert Borough Council v. Johnson [1979] 2 N.Z.L.R. 234 | Confirmed in NZ that a purchaser can recover in tort for economic loss associated with physical damage; suggested cause arises when damage occurs or when defect becomes apparent (preferably when apparent). | Relied on by the Court of Appeal and by the Privy Council as establishing the NZ position on duty and the discoverability approach to accrual. |
| Anns v. Merton London Borough Council [1978] AC 728 | Principle that a council must take reasonable care to ensure builders do not cover up byelaw-noncompliant foundations; influential on early NZ cases. | Noted as an English case that reinforced the line of NZ authority in earlier years; cited as part of the historical background. |
| Brown v. Heathcote County Council [1986] 1 N.Z.L.R. 76 | Applied Bowen and Mount Albert to other building defect situations; emphasized NZ development of negligence law and reliance elements. | Cited as part of the important group of NZ decisions extending the principle; also the Privy Council had earlier considered Brown on appeal. |
| Stieller v. Porirua City Council [1986] 1 N.Z.L.R. 84 | Part of the 1986 group applying NZ principles to building defects. | Included among the series of NZ cases that extended the principle to diminution in value even without manifest physical damage. |
| Craig v. East Coast Bays City Council [1986] 1 N.Z.L.R. 99 | Another NZ decision in the line extending council liability for building defects. | Used to demonstrate the consistent NZ line of authority. |
| Williams v. Mount Eden Borough Council [1986] 1 N.Z.B.L.C. 102,544 | Recognised element of general reliance by purchasers and helped establish duty based on council control and public expectation. | Quoted at length in the opinion to show the reliance and expectation underpinning NZ decisions. |
| Hedley Byrne & Co. Ltd. v. Heller & Partners Ltd. [1964] AC 465 | Assumption of responsibility and reliance as foundations for a duty in negligent misstatement contexts. | The council argued Hedley Byrne had no application; the Privy Council noted that Hedley Byrne-type reliance had long been an element in NZ cases and rejected the contention that reliance was novel. |
| D. & F. Estates Ltd. v. Church Commissioners for England [1989] AC 177 | House of Lords decision acknowledging certain NZ authorities; referenced in argument as English authority the council sought to follow. | Cited by the council as authority to be followed; the Privy Council treated D. & F. as part of the English developments but held that NZ could diverge for good reasons. |
| Murphy v. Brentwood District Council [1991] 1 AC 398 | House of Lords decision limiting or rejecting liability for pure economic loss in defective building contexts and overruling earlier English authorities. | The council urged adoption of Murphy's approach; the Privy Council held that Murphy should not displace the NZ line of authority given NZ circumstances and statutory background. |
| Pirelli General Cable Works Ltd. v. Oscar Faber & Partners [1983] 2 AC 1 | Held (in House of Lords) that cause of action accrues when damage comes into existence even if undiscovered (criticised as producing injustice in latent defect cases). | The council urged following Pirelli on limitation; the Privy Council upheld the NZ approach (discoverability) and rejected importing Pirelli into NZ law for latent building defects. |
| Askin v. Knox [1989] 1 N.Z.L.R. 248 | Reiterated that NZ judges should follow Mount Albert's guidance on limitation and suggested Parliament consider a statutory longstop. | Quoted to show prior NZ authority continuing the discoverability approach and urging statutory reform (which later occurred in Building Act 1991). |
| Cartledge v. E. Jopling & Sons Ltd. [1963] A.C. 758 | Lord Reid's observations about accrual and discoverability in personal injury context were discussed in relation to limitation principle. | The Privy Council analysed Cartledge as part of the limitation debate and explained why Pirelli's reliance on parts of Cartledge was suspect. |
| Dennis v. Charnwood Borough Council [1983] Q.B. 409 | Stated limitation begins when damage or an event reveals the breach or when a prudent owner would investigate; used to mark the discoverability trigger. | Quoted approvingly for the proposition that time begins when defects become obvious enough to justify a reasonable owner calling in an expert. |
| Ruxley Electronics and Construction Ltd. v. Forsyth [1996] 1 A.C. 344 | Authority on measure of loss (cost of repair if reasonable, otherwise market depreciation). | Cited for the appropriate measure of loss once discoverability triggers accrual (cost of repair or depreciation). |
| Hope v. Manukau City Council (unreported, 2 Aug 1976) | An early NZ instance of inferring purchaser reliance on compliance with byelaws even where direct evidence was lacking. | Quoted to show that general reliance by purchasers had been accepted in NZ law for many years. |
| Mount Albert City Council v. New Zealand Municipalities Co-operative Insurance Co. Ltd. [1983] N.Z.L.R. 190 | Described the line of authority (following Dutton) as depending on council control and thus creating a duty. | Used to illustrate that NZ authority grounded duties on the council's control over building. |
| Chase v. de Groot [1994] 1 N.Z.L.R. 613 | Another foundations case where Tipping J. followed NZ Court of Appeal authority rather than Murphy. | Noted as an example of NZ judges preferring the NZ line of authority to Murphy. |
| South Pacific Manufacturing Co. Ltd. v. New Zealand Security Consultants & Investigations Ltd. [1992] 2 N.Z.L.R. 282 | Cooke P. concluded Murphy should not lead to change in NZ approach to negligence. | Cited as authority where Cooke P. maintained the NZ approach to negligence over Murphy. |
| City of Kamloops v. Nielsen (1984) 10 D.L.R. (4th) 641 | Canadian authority holding municipalities may be liable for economic loss from defective foundations. | Cited to show other common law jurisdictions (Canada) permitted recovery and rejected Pirelli/Murphy approach; used to support NZ divergence. |
| Canadian National Railway Co. v. Norsk Pacific Steamship Co. Ltd. (1992) 91 D.L.R. (4th) 289 | Majority followed Kamloops and declined to follow Murphy; endorsed case-by-case categories allowing recovery of economic loss where justifiable. | Quoted to show international judicial rejection of the narrow exclusionary rule and support for discoverability/reasoned categories. |
| Winnipeg Condominium Corporation No. 36 v. Bird Construction Co. (1995) 121 D.L.R. (4th) 193 | Recent Canadian Supreme Court authority reaffirming the Kamloops approach. | Referred to as continuing Canadian support for recovery of economic loss in building defect cases. |
| Council of the Shire of Sutherland v. Heyman (1985) 157 C.L.R. 424 | Australian High Court initially declined municipal liability for economic loss from defective foundations. | Quoted to illustrate differing approaches in Australia and to explain references in later English judgments; noted the later Australian change in Bryan v. Maloney. |
| Bryan v. Maloney (1995) 69 A.L.J.R. 375 | Australian decision holding negligent builder liable to subsequent purchaser for economic loss; majority based decision on assumption of responsibility and reliance. | Cited to show that Australia had moved to an approach consistent with the NZ twin concepts of assumption of responsibility and reliance and to support the legitimacy of the NZ approach. |
| Governors of Peabody Donation Fund v. Sir Lindsay Parkinson & Co. Ltd. [1985] AC 210 | Referenced in discussion of related authorities surviving other decisions. | Mentioned as part of judicial background in reconciling various results; cited as contextual authority. |
| Batty v. Metropolitan Property Realisations Ltd. [1978] Q.B. 554 | Referred to by D. & F. analysis as a case of pure economic loss. | Used in tracing the distinction between physical damage and pure economic loss in the jurisprudence discussed. |
| Australian Consolidated Press Ltd. v. Uren [1969] 1 AC 590 | Quoted on the point that a considered alternative view can be respectable and lawful. | Referenced to support the proposition that divergent but respectable reasoning in different jurisdictions cannot be labelled wrong as a matter of logic. |
| Cartledge v. E. Jopling & Sons Ltd. [1963] A.C. 758 | Discussed concerning accrual and discoverability in personal injury cases; its dicta were appealed to in later limitation debates. | Cited in the opinion to explain why Pirelli's reliance on Cartledge was open to criticism. |
| Ketteman v. Hansel Properties Ltd. [1987] A.C. 189 | Mentioned with reference to Lord Fraser's comments about buildings 'doomed from the start'. | Cited only in passing as part of the literature around Pirelli and latent defect reasoning. |
| Bagot v. Stevens Scanlan & Co. Ltd. [1966] 1 Q.B. 197 | Early authority referred to in Lord Denning's reasoning in Dutton and related cases. | Discussed as historical context for Denning M.R.'s view in Dutton. |
| Sparham-Souter v. Town and Country Developments (Essex) Ltd. [1976] Q.B. 858 | Court of Appeal held cause of action accrues when defect becomes apparent (distinguishing Cartledge). | Noted as an English stage in the limitation debate; later overruled by Pirelli in the House of Lords. |
| Latent Damage Act 1986 (England) | Statutory reform creating a 'longstop' limitation in latent damage cases in England. | Cited in the opinion to show that criticism of Pirelli in England had been addressed by statutory reform; contrasted with NZ legislative choices. |
| Limitation Act 1950 (New Zealand) / Limitation Act 1963 (England) | Statutory background relevant to accrual and postponement of limitation periods. | Discussed as part of the limitation analysis and as influencing earlier judicial approaches to accrual and discoverability. |
| Building Act 1991 (New Zealand), ss. 90–91 | New Zealand statute addressing civil proceedings against building certifiers and imposing a 10-year rule for certain proceedings; contemplates tort claims against certifiers and authorities. | The Privy Council relied on the Act to support the view that NZ Parliament did not intend to abrogate the existing common law and that statutory background supported continuation of the NZ approach to duties and limitation. |
| Hart v. O'Connor [1985] AC 1000; Tai Hing Cotton Mill Ltd. v. Liu Chong Hing Bank Ltd. [1986] AC 80; Broome v. Cassell & Co. Ltd. [1972] AC 1027 | Authorities on appellate functions and the ability of final appellate courts to ensure correct application of common law principles. | Referred to in the context of when the Privy Council should correct purported misapplications of English common law in a dominion court. |
Court's Reasoning and Analysis
The Privy Council's analysis addressed the two central issues (duty of care and limitation) by reference to the New Zealand line of authority, comparative common-law approaches, and the relevant statutory background.
On the duty of care:
- The Board observed that the New Zealand Court of Appeal's unanimous conclusion that the council owed a duty of care was consistent with nearly 20 years of NZ jurisprudence beginning with Bowen and followed in subsequent NZ cases. Those cases grounded the duty on the twin concepts of the council's control over building work and the reasonable reliance by purchasers/owners on the council's exercise of statutory building control.
- Although the House of Lords in Murphy had taken a different English approach, the Privy Council emphasised that common law in different jurisdictions may legitimately develop differently in response to local circumstances. The NZ courts had consciously departed from the changing English line on the basis that NZ conditions and community expectations differed, and the Board accepted that course.
- The Board rejected the council's contention that adopting a Hedley Byrne type approach (assumption of responsibility/reliance) was novel in NZ: the opinion cites NZ authorities (including Hope and Williams) showing general reliance by purchasers had long been a feature of NZ law.
- The Privy Council also noted policy and statutory differences between England and New Zealand (in particular the absence in NZ of an exact equivalent to the English Defective Premises Act 1972 and the presence of NZ's Building Act 1991, which contemplates continuing private tort claims). Those differences reinforced the conclusion that NY law need not be conformed to Murphy.
On limitation (when the cause of action accrues):
- The Board confined its remarks to latent defects in buildings. It reviewed the competing approaches: (a) the Pirelli approach that a cause of action accrues when the damage exists (even if undiscovered), and (b) the discoverability approach (adopted in NZ cases) that the cause of action accrues when the defect becomes apparent or reasonably discoverable so that the market value is affected or a reasonable owner would obtain expert advice.
- The Board accepted the NZ approach as more sensible in the latent defect context: economic loss occurs when the market value of the house is depreciated (i.e., when the defect is known or manifest) and not merely when an undiscoverable defect exists. This avoids injustice where a plaintiff could be time-barred before any loss is experienced and is consistent with policy considerations and comparative jurisprudence (e.g., Canadian decisions rejecting Pirelli).
- The Board adopted the test that the cause of action accrues when cracks or defects become so obvious that a reasonable homeowner would call in an expert (citing Dennis v. Charnwood Borough Council) and observed that it is not possible to define the precise moment more accurately in general terms.
- The Board expressly confined its advice on limitation to latent building defect cases and declined to opine on the broader applicability of the reasonable discoverability test in other tort contexts.
Application to the facts:
- Applying those principles, the Board accepted the factual findings (concurrent findings) that: the inspector negligently approved foundations on 1 June 1972; some cracks appeared in 1974 and worsened over subsequent years; but a reasonably prudent homeowner would not have discovered the cause of the defects until 1989 when the plaintiff called in an expert.
- Because accrual is triggered by discoverability (when the economic loss occurs), the plaintiff's proceedings (issued November 1990) were in time. The judge had applied the correct test in law and his factual conclusions were not disturbed.
Holding and Implications
Holding: Their Lordships will humbly advise Her Majesty that the appeal should be DISMISSED.
Immediate consequences (direct effect on the parties):
- The Court of Appeal's decision in favour of the plaintiff is affirmed by the Privy Council; the plaintiff's tort claim against the council was held not to be time-barred and the finding of negligence and damages assessed below stand.
- By agreement, there will be no order as to costs.
Broader implications (as stated in the opinion):
- The Privy Council affirmed the New Zealand approach to duty in building inspection contexts — founded on control and reliance — and declined to import the restrictive approach of Murphy v. Brentwood into New Zealand law.
- On limitation for latent building defects, the Board endorsed the discoverability test (cause of action accrues when the defect is known or reasonably discoverable and the market value is affected) as the appropriate principle in New Zealand for such cases. The Board confined this holding to latent defects in buildings and did not purport to extend it beyond that context.
- The opinion recognises divergent approaches among common-law jurisdictions and stresses that such divergence may be appropriate given different statutory frameworks and community expectations; the Building Act 1991 in New Zealand (and its provisions on civil proceedings and limitation) supported maintaining the NZ approach rather than adopting Murphy.
- The decision does not purport to change the law in other jurisdictions (notably England) and the Board expressly said it was not for them to declare Pirelli or Murphy good or bad law in England; but it stated clearly that Pirelli/Murphy do not govern New Zealand law on these points.
This summary is drawn exclusively from the text of the provided opinion of the Judicial Committee of the Privy Council in Invercargill City Council v Hamlin (12 February 1996) as supplied.
JISCBAILII_CASE_TORT
Invercargill City Council Appellant v. Hamlin Respondent (New Zealand) [1996] UKPC 56 (12 February 1996)
Privy Council Appeal - 1996
Invercargill City Council
Appellant
v.
Hamlin
Respondent
FROM
THE COURT OF APPEAL OF
THE
NEW ZEALAND
---------------
JUDGMENT OF THE LORDS OF THE
JUDICIAL
COMMITTEE
OF THE PRIVY COUNCIL,
Delivered
the 12th Feburary 1996
------------------
Present at the
hearing:-
Lord
Browne-Wilkinson
Lord Keith of Kinkel
Lord Browne-Wilkinson
Lord Mustill
Lord Lloyd of Berwick
Sir Michael Hardie Boys
[Delivered by
Lord Lloyd of Berwick]
------------------
In May 1972, the plaintiff, Noel Gordon Hamlin, entered into an agreement
with a firm of builders whereby they sold him some land at 67, Edinburgh
Crescent, Invercargill, and agreed to build him a house. A building inspector
employed by the Invercargill City Council carried out a number of inspections
in the course of construction, as required by the city byelaws. On 1 June 1972
the inspector approved the foundations. 17 years later the plaintiff called in
another builder, who told him that the foundations were defective. In November
1990 the plaintiff commenced proceedings against the council as well as the
builders claiming $64,250 as the cost of repairs.
The case came before Williamson J. on 8 June 1992. He held that the builders
were in breach of contract, since the foundations were not laid in accordance
with the specification. But, as so often happens, the builders were no longer
in business. So the plaintiff's prospect of recovering damages depended on his
claim in tort against the council. The judge held that the building inspector
had been negligent in carrying out his inspection. In his report the inspector
had noted 'clay 15 inches siting approved.' But along the eastern wall the
foundations were only seven to eight inches deep. According to the expert
evidence which the judge accepted the inspector could have discovered without
difficulty that the foundations had not been carried down to firm clay.
A number of cracks, and other minor defects, had appeared over the
years. But the judge found that a reasonably prudent homeowner would not have
suspected the foundations, or discovered the cause of the trouble until 1989,
when the plaintiff called in the second builder. It followed that, as New
Zealand law then stood, his claim against the council was in time. Since it
was admitted, for the purposes of the hearing before the judge, that the
council was under a duty of care towards the plaintiff, the judge upheld the
plaintiff's claim. He assessed the damages at $53,550.
The council appealed. There were two main issues for determination. Since
the concession made in the court below was not binding in the Court of Appeal,
the first question was whether the council owed any duty of care to the
plaintiff at all. The council argued that the Court of Appeal ought to follow
the decisions of the House of Lords in D. & F. Estates Ltd. v. Church
Commissioners for England [1989] AC 177 and Murphy v. Brentwood District
Council [1991] 1 AC 398.
The second question was whether the plaintiff's claim was time-barred. The
council argued that the Court of Appeal ought to follow the decision of the
House of Lords in Pirelli General Cable Works Ltd. v. Oscar Faber & Partners
[1983] 2 A.C. 1, in other words, that the cause of action accrued when the
damage to the house came into existence, and not when it could with reasonable
diligence have been discovered. On that view the plaintiff issued his writ too
late.
The appeal came before a full court of five judges [1994] 3 N.Z.L.R 513.
They answered the first question unanimously in favour of the plaintiff. They
answered the second question by a majority in favour of the plaintiff with
McKay J. dissenting. Their Lordships would wish to pay tribute to the very
high quality of all five judgments.
There can be no doubt that the decision of the Court of Appeal is in
accordance with the law as it has been developed by New Zealand courts over
the last 20 years. A convenient starting point is Bowen v. Paramount Builders
(Hamilton) Ltd. [1975] 2 N.Z.L.R. 546, since it was also a case concerning
inadequate foundations. The sole defendant in that case was the builder, and
the plaintiff was a purchaser from the original owner. The case was decided
shortly after the English decision in Dutton v. Bognor Regis Urban District
Council [1972] 1 Q.B. 373. In Dutton's case the local authority was held
liable for the negligence of the building inspector on facts very similar to
the present case. Speight J., at first instance, declined to follow Dutton's
case. But his decision was reversed in the Court of Appeal [1977] 1 N.Z.L.R.
394. The leading judgment was given by Richmond P., who, as it happens,
dissented on the facts. But there was no disagreement as to the principle. The
case was treated as one involving physical damage to the premises. The court
did not find it necessary to deal with the question of 'pure' economic loss,
that is to say, economic loss unassociated with physical harm to the structure
itself. The point was left open for the future.
In Mount Albert Borough Council v. Johnson [1979] 2 N.Z.L.R. 234 the
plaintiff, a subsequent purchaser, brought proceedings against the council for
failing to ensure that the foundations were adequate. The council brought
in the builders as third party. By the time the case reached the Court of
Appeal, the House of Lords had decided Anns v. Merton London Borough Council
[1978] AC 728. Lord Wilberforce said in that case, at p. 758, that it was
the duty of the council 'to take reasonable care, no more, no less, to secure
that the builder does not cover in foundations which do not comply with byelaw
requirements.'
The leading judgment in Mount Albert Borough Council v. Johnson [1979] 2
N.Z.L.R. 234 was given by Cooke P. It was, he said, at p. 239, current law in
New Zealand that a purchaser in the plaintiff's position can recover in tort
for economic loss caused by negligence, 'at least when the loss is associated
with physical damage.'
In a subsequent and related case brought by the council against their
insurers, Cooke P. described the line of authority following on Dutton's case
[1972] 1 Q.B. 373 as depending on control: see Mount Albert City Council v.
New Zealand Municipalities Co-operative Insurance Co. Ltd. [1983] N.Z.L.R.
190, 196: 'The local authority's control of building in its district has been
held to carry a duty to take reasonable care in performing the statutory
functions.'
Next there came a group of cases all decided in 1986: Brown v. Heathcote
County Council [1986] 1 N.Z.L.R. 76, Stieller v. Porirua City Council [1986] 1
N.Z.L.R. 84, Craig v. East Coast Bays City Council [1986] 1 N.Z.L.R. 99 and
Williams v. Mount Eden Borough Council [1986] 1 N.Z.B.L.C. 102, 544. These
cases applied the principles stated in Bowen v. Paramount Builders (Hamilton)
Ltd. [1975] 2 N.Z.L.R. 546 and Mount Albert Borough Council v. Johnson [1979]
2 N.Z.L.R. 234 to building defects other than faulty foundations. They are
important because they extended the principle to cases where there was no
physical damage as such, nor any certainty that there would be. It was enough
that the value of the premises had been reduced. Whether it is right to
describe such cases as instances of 'pure' economic loss may not matter very
much. They do not depend on pure economic loss in the sense of White v. Jones
[1995] 2 AC 207 or Henderson v. Merrett Syndicates Ltd. [1995] 2 AC 145.
For in the building cases the economic loss is suffered by reason of a defect
in a physical object.
Secondly the cases are important because they recognise the element of
reliance in establishing a duty of care in economic loss cases. Thus in
Williams v. Mount Eden Borough Council [1986] 1 N.Z.B.L.C. 102,544, 102,551
Casey J. said:
"Having had these powers in relation to the construction of buildings
conferred on it, the reasonable local authority would no doubt have accepted
that they were intended to be exercised for the protection of those members of
the public concerned with those buildings, whether as owners, occupiers or
users. No doubt it would also have appeared to such an authority that many of
them would have no opportunity or expectation of checking or controlling
hidden details in its construction to ensure that appropriate standards had
been complied with, relating to its physical soundness, its ability to
withstand earthquake shocks, and the safety and health of its occupants.
Conversely, those members of the public would have been aware that local
bodies exercised this kind of control over buildings constructed in their
districts; this has been a known fact of at least New Zealand urban life for
several generations. The statement by Mrs. Williams that her knowledge of the
Mount Eden Borough Council as 'the toughest' and her assumption that
everything would be all right, reflects what I am sure all these plaintiffs
and most of the community at large would have felt. Work essential to the
structural integrity of a building and its earthquake resistance is almost
invariably covered in, and in the usual house buying situation, purchasers
have to rely on the council doing its job properly under the building controls
conferred on it. I am also satisfied that the latter and its officers would
have been well aware that such reliance was placed upon it by the community at
large, especially in this case where they must have realised the builder was
likely to sell the units; and that there was no feasible way any purchaser
could have discovered hidden structural defects."
Lastly these cases are important because they mark the point at which Cooke
P. felt able to say in Brown v. Heathcote County Council [1986] 1 N.Z.L.R. 76,
79:
"The lineaments of the contemporary New Zealand law of negligence in this
and related fields are now, I think, reasonably firmly established by a series
of cases; but in the main it is law of comparatively recent growth, largely
though by no means exclusively evolved since the appeal in Bowen was allowed
in this court. . . ."
The facts of Brown v. Heathcote County Council were that the plaintiffs
built a house on a site which, unknown to them, was subject to flooding. They
incurred expenditure of $32,000 in raising the level of the floor. They
brought an action against the council and the drainage board for negligence.
They succeeded against the board before Hardie Boys J. and the Court of
Appeal, on the ground that the board should have warned them of the danger of
flooding. In the course of his judgment Cooke P., at pp. 80-82, pointed out
that the facts bore some resemblance to those in Dennis v. Charnwood Borough
Council [1983] Q.B. 409, a decision which had survived Governors of Peabody
Donation Fund v. Sir Lindsay Parkinson & Co. Ltd. [1985] AC 210, 243-245.
But reconciling the results in particular cases in this field was not, he
thought, of the highest priority. He clearly foresaw the time when New Zealand
law might 'go its own way' having regard to the special circumstances
prevailing in that country.
The board appealed to the Privy Council [1987] 1 N.Z.L.R. 720. The appeal
was dismissed. Their Lordships did not find it necessary in that case to
consider the many authorities discussed in the courts below. For the appeal
turned on a straightforward question whether a sufficient degree of proximity
existed between the board and the plaintiffs. Their Lordships answered that
question in favour of the plaintiffs. Although the board had not been asked by
the council to check the flood levels, they habitually did so. Accordingly
they assumed a duty of care under the principle stated in Hedley Byrne & Co.
Ltd. v. Heller & Partners Ltd. [1964] AC 465, not only towards the council,
but also towards the plaintiffs.
Two years later the position which had by then been reached in New
Zealand was recognised by the House of Lords in D. & F. Estates Ltd. v. Church
Commissioners for England [1989] AC 177. After referring to Batty v.
Metropolitan Property Realisations Ltd. [1978] Q.B. 554, a case which Lord
Oliver of Aylmerton analysed as one of pure economic loss, he continued [1989] AC 177, 216:
"As in Anns v. Merton London Borough Council [1978] AC 728, the cause of
action was related not to damage actually caused by the negligent act but to
the creation of the danger of damage, and the case is therefore direct
authority for the recovery of damages in negligence for pure economic loss - a
proposition now firmly established in New Zealand: see Mount Albert Borough
Council v. Johnson [1979] 2 N.Z.L.R 234.'
Lord Bridge of Harwich said, at p. 207:
"I should wish to hear fuller argument before reaching any conclusion as
to how far the decision of the New Zealand Court of Appeal in Bowen v.
Paramount Builders (Hamilton) Ltd. should be followed as a matter of English
law. I do not regard Anns v. Merton London Borough Council as resolving that
issue."
Their Lordships can turn now to the decision of the Court of Appeal in the
instant case, while noting on the way that in Chase v. de Groot [1994] 1
N.Z.L.R. 613, yet another foundations case, Tipping J. followed the many
previous decisions of the New Zealand Court of Appeal, in preference to the
intervening decision of the House of Lords in Murphy v. Brentwood District
Council [1991] 1 AC 398; and in South Pacific Manufacturing Co. Ltd. v. New
Zealand Security Consultants & Investigations Ltd. [1992] 2 N.Z.L.R. 282 Cooke
P. concluded in agreement with the four other members of the court that the
decision in Murphy's case [1991] 1 AC 398 should not lead to any change in
the approach to negligence cases in New Zealand.
In the present case, Cooke P. [1994] 3 N.Z.L.R. 513, 519 observed that ' the
linked concepts of reliance and control' had underlain the New Zealand case
law from Bowen's case [1977] 1 N.Z.L.R. 394 onwards; he also regarded the
decision of the Privy Council in Brown v. Heathcote County Council [1987] 1
N.Z.L.R. 720 (to which their Lordships have just referred) as an important
authority in favour of the plaintiff's claim in the present case.
Their Lordships need not analyse the other four judgments. They are all
founded on what the court regarded as a consistent line of authority starting
with Bowen's case [1977] 1 N.Z.L.R. 394 in 1975, and thus stretching back over
a period of nearly 20 years.
Miss Bates, for the council, attacks the decision on a number of grounds.
Quite apart from the about turn which the House of Lords executed in Murphy's
case [1991] 1 AC 398, she submits that the decision represents a departure
from the previous line of authority in New Zealand. The previous cases (so it
was argued) were all based on a straightforward application of the principle
in Donoghue v. Stevenson [1932] AC 562. In the present case the court seems
for the first time to have imposed a duty of care on the basis of Hedley
Byrne & Co. Ltd. v. Heller & Partners Ltd. [1964] AC 465. But there was no
evidence that the council ever assumed responsibility for economic loss caused
by the builders' failure to comply with the building byelaws; nor was there
any evidence of any reliance by the plaintiff. Indeed reliance was not even
pleaded.
Their Lordships are unable to accept this argument. Hedley Byrne & Co. Ltd.
v. Heller & Partners was scarcely mentioned in the court below. Moreover
general reliance (as distinct from specific reliance established on the facts
of a particular case) has been a feature of this branch of New Zealand law for
many years. As early as 1976 Chilwell J. said in Hope v. Manukau City Council
(unreported), 2 August 1976:
"There is no direct evidence that the plaintiff relied upon the flat
having been built in accordance with the byelaws and regulations. She did not
say that she did. But she did say that she saw the plans and specification
before she agreed to purchase the flat. . . . I would be prepared to draw the
inference as a matter of common sense that the average prudent purchaser of a
new residential flat expects that the byelaws and regulations will have been
complied with. I would classify this plaintiff as an average purchaser. In our
cities there would be few citizens who would be unaware of the necessity for
buildings to comply with the byelaws and health regulations and unaware of the
control which city councils exercise over building works."
The same point was made by Casey J. 10 years later in Williams v. Mount Eden
Borough Council [1986] 1 N.Z.B.L.R. 102,544, 102,551, in a passage which has
already been quoted, and by Cooke P. in the South Pacific Manufacturing Co.
case [1992] 2 N.Z.L.R. 282, 297. So there was nothing new in the concept of
reliance by house buyers generally as an element in the imposition of a duty
of care. Cooke P. drew attention in that connection to Housing in New Zealand:
Report of the Commission of Inquiry (1971), over which he presided. He made
the following comment [1994] 3 N.Z.L.R. 513, 519:
"whatever may be the position in the United Kingdom, homeowners in New
Zealand do traditionally rely on local authorities to exercise reasonable care
not to allow unstable houses to be built in breach of the byelaws."
But even if (which their Lordships doubt) it were possible to detect in the
present case an increased emphasis on reliance when compared with previous
cases that is just the sort of change of emphasis which is to be expected in a
developing branch of the common law. Were it not for the intervening decisions
of the House of Lords in D. & F. Estates Ltd. v. Church Commissioners for
England [1989] AC 177 and Murphy v. Brentwood District Council [1991] 1 AC 398, it is unlikely that the present case would ever have reached the Board at
all, at any rate on the duty of care point. It is to consider the impact of
those decisions on New Zealand law that their Lordships now turn.
Miss Bates's argument can be stated in very simple terms. The decision in
Bowen's case [1977] 1 N.Z.L.R. 394 was explicitly based on the English
decision in Dutton v. Bognor Regis Urban District Council [1972] 1 Q.B. 373.
The authority of the line of cases which followed Bowen's case [1977] 1
N.Z.L.R. 394 was reinforced by the decision of the House of Lords in Anns v.
Merton London Borough Council [1978] AC 728. Both those English cases are
now known to have been wrongly decided. If English law had not taken a wrong
turning in 1972, New Zealand law would never have followed. The present appeal
affords an opportunity for the Board, as the final appellate court for New
Zealand, to put New Zealand law back on the correct path.
Where the New Zealand Court of Appeal is purporting to apply settled
principles of English common law, then it is the function of the Board to
ensure that those principles are applied correctly. Hart v. O'Connor [1985] AC 1000 was such a case, and Lord Scarman's observations in Tai Hing Cotton
Mill Ltd. v. Liu Chong Hing Bank Ltd. [1986] AC 80, 108 are to be understood
in that light.
But in the present case the judges in the New Zealand Court of Appeal were
consciously departing from English case law on the ground that conditions in
New Zealand are different. Were they entitled to do so? The answer must surely
be 'Yes.' The ability of the common law to adapt itself to the differing
circumstances of the countries in which it has taken root, is not a weakness,
but one of its great strengths. Were it not so, the common law would not have
flourished as it has, with all the common law countries learning from each
other. The point was put by Lord Diplock in a very different context in Broome
v. Cassell & Co. Ltd. [1972] AC 1027, 1127:
"Other supreme appellate tribunals exercise a similar function in other
countries which have inherited the English common law at various times in the
past. Despite the unifying effect of that inheritance upon the concept of
man's legal duty to his neighbour, it does not follow that the development of
the social norms in each of the inheritor countries has been identical or will
become so. I do not think that your Lordships should be deflected from your
function of developing the common law of England and discarding judge-made
rules which have outlived their purpose and are contrary to contemporary
concepts of penal justice in England, by the consideration that other courts
in other countries do not yet regard an identical development as appropriate
to the particular society in which they perform a corresponding function."
By the same token, the Court of Appeal of New Zealand should not be deflected
from developing the common law of New Zealand (nor the Board from affirming
their decisions) by the consideration that the House of Lords in D. & F.
Estates Ltd. v. Church Commissioners for England [1989] AC 177 and Murphy v.
Brentwood District Council [1991] 1 AC 398 have not regarded an identical
development as appropriate in the English setting.
The particular branch of the law of negligence with which the present appeal
is concerned is especially unsuited for the imposition of a single monolithic
solution. There are a number of reasons why this is so. The first and
most obvious reason is that there is already a marked divergence of view among
other common law jurisdictions.
In Canada it is well established that a municipality may be liable for
economic loss caused by the negligence of a building inspector. Thus in City
of Kamloops v. Nielsen (1984) 10 D.L.R. (4th) 641, the facts of which were
very similar to the present case, the plaintiff, a subsequent purchaser, sued
the municipality for failing to prevent his house being built with defective
foundations in breach of a local byelaw. He also sued the builder. He
succeeded against both defendants. The Kamloops case was decided before
Murphy's case [1991] 1 AC 398. But in a subsequent case, a majority of the
Supreme Court followed the Kamloops case, 10 D.L.R. (4th) 641, and declined to
follow Murphy's case [1991] 1 AC 398: see Canadian National Railway Co. v.
Norsk Pacific Steamship Co. Ltd. (1992) 91 D.L.R. (4th) 289. McLachlin J.
said, at p. 365:
"The fact is that situations arise, other than those falling within the
old exclusionary rule, where it is manifestly fair and just that recovery of
economic loss be permitted. Faced with these situations, courts will strain to
allow recovery, provided they are satisfied that the case will not open the
door to a plethora of undeserving claims. They will refuse to accept injustice
merely for the sake of the doctrinal tidiness which is the motivating spirit
of Murphy. This is in the best tradition of the law of negligence, the history
of which exhibits a sturdy refusal to be confined by arbitrary forms and rules
where justice indicates otherwise. It is the tradition to which this court has
adhered in suggesting in Kamloops that the search should not be for a
universal rule but for the elaboration of categories where recovery of
economic loss is justifiable on a case-by-case basis."
A little later she said, at p. 371:
"I conclude that, from a doctrinal point of view, this court should
continue on the course chartered in Kamloops rather than reverting to the
narrow exclusionary rule as the House of Lords did in Murphy."
The same approach was reaffirmed unanimously in a recent decision of the
Supreme Court: see Winnipeg Condominium Corporation No. 36 v. Bird
Construction Co. (1995) 121 D.L.R. (4th) 193.
In Australia, the High Court at first declined to hold local authorities
liable for economic loss suffered by reason of houses being built with
defective foundations: see Council of the Shire of Sutherland v. Heyman (1985)
157 C.L.R. 424. A lengthy passage from Brennan J.'s judgment in that case was
quoted with approval by Lord Keith of Kinkel in Murphy's case [1991] 1 AC 398, 467-468. But 10 years later Brennan J. found himself in a minority of one
when the High Court changed tack. In Bryan v. Maloney (1995) 69 A.L.J.R. 375
it was held that a negligent builder was liable for economic loss suffered by
a subsequent purchaser. Mason C.J. referred to the D. & F. Estates case [1989] AC 177 and Murphy's case [1991] 1 AC 398 and continued, 69 A.L.J.R. 375,
383:
"It is, however, apparent that, in each case, their Lordships considered
that a negligent builder's liability under the law of negligence did not
extend to compensating either the first or a subsequent owner for economic
loss sustained when the inadequacy of the footings of a building first becomes
manifest by reason of consequent damage to the fabric of the building. Their
Lordships' view in that regard seems to us, however, to have rested upon a
narrower view of the scope of the modern law of negligence and a more rigid
compartmentalisation of contract and tort than is acceptable under the law of
this country."
Their Lordships cite these judgments in other common law jurisdictions not
to cast any doubt on Murphy's case [1991] 1 AC 398, but rather to illustrate
the point that in this branch of the law more than one view is possible: there
is no single correct answer. In Bryan v. Maloney, 69 A.L.J.R. 375 the majority
decision was based on the twin concepts of assumption of responsibility and
reliance by the subsequent purchaser. If that be a possible and indeed
respectable view, it cannot be said that the decision of the Court of Appeal
in the present case, based as it was on the same or very similar twin
concepts, was reached by a process of faulty reasoning, or that the decision
was based on some misconception: see Australian Consolidated Press Ltd. v.
Uren [1969] 1 AC 590, 644.
In truth, the explanation for divergent views in different common law
jurisdictions (or within different jurisdictions of the United States of
America) is not far to seek. The decision whether to hold a local authority
liable for the negligence of a building inspector is bound to be based at
least in part on policy considerations. As Mason C.J. said in Bryan v.
Maloney, 69 A.L.J.R. 375, 377:
"Inevitably, the policy considerations which are legitimately taken into
account in determining whether sufficient proximity exists in a novel category
will be influenced by the court's assessment of community standards and
demands."
In a succession of cases in New Zealand over the last 20 years it has been
decided that community standards and expectations demand the imposition of a
duty of care on local authorities and builders alike to ensure compliance with
local byelaws. New Zealand judges are in a much better position to decide on
such matters than the Board. Whether circumstances are in fact so very
different in England and New Zealand may not matter greatly. What matters is
the perception. Both Richardson and McKay JJ. [1994] 3 N.Z.L.R. 513, 528, 546
in their judgments in the court below stress that to change New Zealand law so
as to make it comply with Murphy's case [1991] 1 AC 398 would have '
significant community implications' and would require a 'major attitudinal
shift.' It would be rash for the Board to ignore those views.
In one important respect circumstances prevailing in England at the time of
Murphy's case and those prevailing in New Zealand are indeed very different.
Their Lordships have in mind the statutory background. In Murphy's case the
House of Lords attached great weight to the passing of the Defective Premises
Act 1972. Thus Lord Mackay of Clashfern L.C. said, at p. 457:
"Faced with the choice I am of the opinion that it is relevant to take
into account that Parliament has made provisions in the Defective
Premises Act 1972 imposing on builders and others undertaking work in the
provision of dwellings obligations relating to the quality of their work and
the fitness for habitation of the dwelling. For this House in its judicial
capacity to create a large new area of responsibility on local authorities in
respect of defective buildings would in my opinion not be a proper exercise of
judicial power."
See also per Lord Keith of Kinkel, at p. 472, Lord Oliver of Aylmerton, at p.
491, and Lord Jauncey of Tullichettle, at p. 498.
By contrast there is no legislation corresponding to the Defective Premises
Act 1972 in New Zealand. Instead there was an extended period of research
starting with the Commission of Inquiry into Housing in 1971, and including
the Review of Planning and Building Controls published in 1983, which resulted
eventually in the Building Act 1991. That Act was passed a year and a half
after the decision in Murphy's case. There is nothing in the Act to abrogate
or amend the existing common law, as developed by New Zealand judges, so as to
bring it into line with Murphy's case. On the contrary, a number of provisions
in the Act clearly envisage that private law claims for damages against local
authorities will continue to be made as before. Thus section 90 provides:
"Civil proceedings against building certifiers. Civil proceedings against
a building certifier in respect of the exercise by the building certifier of
the building certifier's statutory function in issuing a building certificate
or a code compliance certificate are to be brought in tort and not in
contract."
Similarly section 91 provides:
"Limitation defences. (1) Except to the extent provided in subsection (2)
of this section, the provisions of the Limitation Act 1950 apply to civil
proceedings against any person where those proceedings arise from - (a) the
construction, alteration, demolition, or removal of any building; or (b) the
exercise of any function under this Act or any previous enactment relating to
the construction, alteration, demolition, or removal of that building. (2)
Civil proceedings may not be brought against any person 10 years or more after
the date of the act or omission on which the proceedings are based. (3) For
the purposes of subsection (2) of this section if - (a) civil proceedings are
brought against a territorial authority, a building certifier, or the
authority; and (b) the proceedings arise out of the issue of a building
consent, a building certificate, a code compliance certificate, or an
authority determination - the date of the act or omission is the date of issue
of the consent or certificate or determination. . . ."
It is neither here nor there that the Building Act 1991 was not in force at
the time of the inspection of the foundations in the present case. The
question is whether New Zealand law should now be changed so as to bring it
into line with Murphy's case. If the New Zealand Parliament has not chosen to
do so, as a matter of policy, it would hardly be appropriate for their
Lordships to do so by judicial decision.
It follows that on the first question their Lordships are content to
adopt the reasoning of the unanimous judgments of the Court of Appeal.
The negligent act or omission of the building inspector in approving the
foundations occurred on 1 June 1972. The first cracks in the masonry veneer,
and in the north wall of the kitchen, appeared in 1974. By 1979 a crack in the
eastern wall had developed to such an extent that a brick was loose. In the
early 1980s the plaintiff noticed some cracks in the foundation wall. Yet
proceedings were not issued until November 1990.
The facts as found by the judge thus raise in an acute form the question
when the plaintiff's cause of action accrued. If the cause of action arose at
the time of the negligent act or omission, or when the first cracks appeared,
then it is obvious that the plaintiff's claim in tort against the council
would be time-barred. But if the cause of action did not accrue until the
plaintiff was advised in 1989 that the foundations were defective, and if, as
the judge found, a reasonably prudent homeowner would not have discovered the
cause of the cracks any earlier, then the proceedings were in time. Which view
is correct?
This is an important question of principle which has been much debated in
recent years in different common law jurisdictions, in a number of different
contexts. Their Lordships propose to confine their advice to the particular
context of latent defects in buildings.
In New Zealand the law has been relatively clear and straightforward since
at least the decision of the Court of Appeal in Mount Albert Borough Council
v. Johnson [1979] 2 N.Z.L.R. 234. That was the case in which, as already
mentioned, Cooke J. said that by the current law of New Zealand a plaintiff
could recover in tort for economic loss 'at least when the loss is associated
with physical damage' Cooke J. continued, at p. 239:
"Such a cause of action must arise, we think, either when the damage
occurs or when the defect becomes apparent or manifest. The latter appears to
be the more reasonable solution. It is powerfully supported by what Lord Reid
said about the common law in Cartledge v. E. Jopling & Sons Ltd. [1963] A.C.
758, 772 . . ."
Ten years later, in Askin v. Knox [1989] 1 N.Z.L.R. 248 the plaintiff
brought an action against a builder and the local authority, alleging
negligence in laying and inspecting the foundations. He failed to prove
negligence on the facts. But Cooke P., giving the judgment of a five judge
court, said that, with regard to limitation, judges in New Zealand should
continue to follow the guidance given by the Court of Appeal in Mount Albert
Borough Council v. Johnson [1979] 2 N.Z.L.R. 234. He foresaw the time when the
matter might have to be reconsidered in the light of the intervening decision
of the House of Lords in Pirelli General Cable Works Ltd. v. Oscar Faber &
Partners [1983] 2 A.C. 1. He commented [1989] 1 N.Z.L.R. 248, 255:
"it does not follow that the reasoning in Pirelli will be irresistible. It
might still be possible to maintain the approach that a cause of action arises
when the defect becomes apparent or ought to have been discovered, that being
the time when the effect of the negligence (whether classified as
physical or economic) is suffered or experienced by the owner of the
building."
He went on to urge Parliament to consider introducing a 'longstop' limitation
period such as the absolute limit of 15 years from the date of the negligent
act or omission contained in the (English) Latent Damage Act 1986. Parliament
acted swiftly on this suggestion: see the Building Act 1991, section 91(2),
already cited.
The foreseen opportunity for reviewing the Pirelli case [1983] 2 A.C. 1
arose in the present case. Williamson J. correctly regarded himself as bound
by Mount Albert Borough Council v. Johnson [1979] 2 N.Z.L.R. 234 and Askin v.
Knox [1989] 1 N.Z.L.R. 248. In the Court of Appeal [1994] 3 N.Z.L.R. 513 Cooke
P., Casey and Gault JJ. reaffirmed the New Zealand approach on limitation, and
pointed out some of the disadvantages of following the Pirelli case [1983] 2
A.C. 1. Not only does that decision mean that a cause of action may become
time-barred before any defect has become apparent (it was this obvious
injustice which led the Supreme Court of Canada to reject the Pirelli decision
in the Kamloops case, 10 D.L.R. (4th) 641), but the reasoning in the Pirelli
case was also suspect, in so far as it was based on certain observations in
the earlier decision of the House of Lords in Cartledge v. E. Jopling & Sons
Ltd. [1963] A.C. 758.
In Cartledge v. E. Jopling & Sons Ltd. (which concerned an action for
personal injuries) Lord Reid had been minded to hold that a cause of action
for personal injuries ought not to accrue until the injured person has
discovered or could reasonably have discovered the injury. 'The common law' he
said, at p. 772, 'ought never to produce a wholly unreasonable result . . .'
But Lord Reid felt constrained by section 26 of the Limitation Act 1939
(corresponding to section 28 of the New Zealand Limitation Act 1950) to reach
just such an unreasonable result. By providing in section 26 for the
postponement of the limitation period in the particular cases of fraud,
mistake and concealment, Parliament must have intended that knowledge of the
injury or damage should be irrelevant in all other cases.
The majority in the court below considered that this did not follow. The
inclusion of three specific instances did not necessarily exclude the general
law. As for the injustice inherent in the Pirelli approach, this was swiftly
cured, so far as English law was concerned, by the Latent Damage Act 1986.
Cooke P. concluded [1994] 3 N.Z.L.R. 513, 523:
"the view that in building negligence cases any cause of action must
accrue on the occurrence of damage to the building itself has been either
wholly or largely abandoned in England by judicial decision, quite apart from
the limitation changes made by the Latent Damage Act. To introduce now the
outmoded English position into New Zealand law would seem a paradoxical and
peculiarly unsatisfactory step."
Richardson J. agreed with the majority on the limitation point.
McKay J., at p. 544, while acknowledging that Lord Reid's speech in
Cartledge v. E. Jopling & Sons Ltd. [1963] A.C. 758 contains a non sequitur,
nevertheless regarded the reasoning in that case and in the Pirellicase [1983]
2 A.C. 1 as compelling. A cause of action has always, he said, been
taken to accrue when all the facts necessary to establish the cause of action
are in existence. In the case of defective foundations that must mean when the
damage occurs whether or not the damage could reasonably have been discovered.
On the facts, McKay J. regarded the cracks in the walls and in the foundation
as more than minimal damage. Accordingly the claim was in his view
time-barred.
Compared with New Zealand the course of English authority has run less
smooth. In Cartledge v. E. Jopling & Sons Ltd. [1963] A.C. 758 the plaintiffs
were workmen who had contracted pneumoconiosis at work. It was held by the
House of Lords that their causes of action were already time-barred before
they could have known that they had suffered any personal injury. The House
called for urgent remedial legislation. But the Limitation Act 1963, passed
later the same year, was confined to actions for personal injuries. It did not
apply to property damage. Accordingly when the Court of Appeal decided Dutton
v. Bognor Regis Urban District Council [1972] 1 Q.B. 373 in 1972, Lord Denning
M.R., relying on a dictum of Diplock L.J. in Bagot v. Stevens Scanlan & Co.
Ltd. [1966] 1 Q.B. 197, 203 (a case concerning defective drains), said [1972]
1 Q.B. 373, 396 that: 'The damage was done when the foundations were badly
constructed.'
But four years later in Sparham-Souter v. Town and Country Developments
(Essex) Ltd. [1976] Q.B. 858 Lord Denning M.R. recanted. The Court of Appeal
held that where a house is built with defective foundations the cause of
action does not accrue until the defect becomes apparent or ought reasonably
to have become apparent. Geoffrey Lane L.J. distinguished Cartledge v. E.
Jopling & Sons Ltd. [1963] A.C. 758 in the following passage [1976] Q.B. 858,
880:
"There is no proper analogy between this situation' - i.e. the situation
in Sparham-Souter's case - 'and the type of situation exemplified in Cartledge
v. E. Jopling & Sons Ltd. where a plaintiff due to the negligence of the
defendants suffers physical bodily injury which at the outset and for many
years thereafter may be clinically unobservable. In those circumstances
clearly damage is done to the plaintiff and the cause of action accrues from
the moment of the first injury albeit undetected and undetectable. That is not
so where the negligence has caused unobservable damage not to the plaintiff's
body but to his house. He can get rid of his house before any damage is
suffered. Not so with his body."
For the seven years following Sparham-Souter's case [1976] Q.B. 858, English
law and New Zealand law went hand-in-hand (on the limitation point).
Unfortunately Sparham-Souter's case was then overruled by the House of Lords
in the Pirelli case [1983] 2 A.C. 1, thereby, presumably, restoring the view
expressed by Lord Denning M.R. in Dutton v. Bognor Regis Urban District
Council [1972] 1 Q.B. 373, until that decision, too, was overruled on the duty
of care point in Murphy's case [1991] 1 AC 398.
Their Lordships refer to the Pirelli case [1983] 2 A.C. 1 as an unfortunate
decision not only because that is how the House itself regarded the
decision - Lord Fraser of Tullybelton, at p. 19, described the result as
unreasonable and contrary to principle - but also because it has been
subjected to a barrage of judicial and academic criticism ever since: see, by
way of example, Michael A. Jones, 'Defective Premises and Subsequent Purchases
- A Comment' (1984) 100 L.Q.R. 413; I. N. Duncan Wallace, ' Negligence and
Defective Buildings: Confusion Confounded?' (1989) 105 L.Q.R. 46 and Todd, The
Law of Torts in New Zealand (1991), p. 912. Their Lordships do not find it
necessary to review these criticisms in any detail, or to enter into the
question what Lord Fraser of Tullybelton may have had in mind when he referred
to buildings which are 'doomed from the start:' see Ketteman v. Hansel
Properties Ltd. [1987] A.C. 189, 207, per Lord Brandon of Oakbrook. Instead
they will quote a passage from an article written shortly after the Pirelli
case [1983] 2 A.C. 1 but before Murphy's case [1991] 1 AC 398, since it
leads on directly to the ground on which the limitation point must now be
decided:
'There is undoubtedly a superficial attraction in the argument which found
favour with all five Lords of Appeal in Pirelli's case. If the nature of the
damage suffered is regarded as a physical loss, it does indeed look as if the
principle in Cartledge v. E. Jopling & Sons Ltd. should apply, on the basis
that the damage is there but is unknown and, it may be, unknowable. But if the
damage is recognised as economic the whole picture changes. It is thought that
a failure to appreciate this point undermines the whole thrust of the argument
in Pirelli's case:' Stephen Todd, 'Latent Defects in Property and the
Limitation Act: A Defence of the 'Discoverability' Test' (1983) 10 N.Z.U.L.R.
311, 316.
This passage is a remarkable anticipation of the reasoning of the House of
Lords in Murphy's case [1991] 1 AC 398.
In Murphy's case [1991] 1 AC 398, 466 Lord Keith of Kinkel said: 'In my
opinion it must now be recognised that, although the damage in Anns [1978] AC 728 was characterised as physical damage by Lord Wilberforce, it was
purely economic loss.' Lord Keith went on, at pp. 467-468, to quote with
approval a lengthy passage from the judgment of Deane J. in Sutherland Shire
Council v. Heyman, 157 C.L.R. 424, 503-505:
'Nor is the respondents' claim in the present case for ordinary physical
damage to themselves or their property. Their claim, as now crystallised, is
not in respect of damage to the fabric of the house or to other property
caused by collapse or subsidence of the house as a result of the inadequate
foundations. It is for the loss or damage represented by the actual inadequacy
of the foundations, that is to say, it is for the cost of remedying a
structural defect in their property which already existed at the time when
they acquired it . . . It is arguable that any such loss or injury should be
seen as being sustained at the time of acquisition when, because of ignorance
of the inadequacy of the foundations, a higher price is paid (or a higher rent
is agreed to be paid) than is warranted by the intrinsic worth of the freehold
or leasehold estate that is being acquired. Militating against that approach
is the consideration that, for so long as the inadequacy of the
foundations is neither known nor manifest, no identifiable loss has come home:
if the purchaser or tenant sells the freehold or leasehold estate within that
time, he or she will sustain no loss by reason of the inadequacy of the
foundations. The alternative, and in my view preferable, approach is that any
loss or injury involved in the actual inadequacy of the foundations is
sustained only at the time when that inadequacy is first known or manifest. It
is only then that the actual diminution in the market value of the premises
occurs. On either approach, however, any loss involved in the actual
inadequacy of the foundations by a person who acquires an interest in the
premises after the building has been completed is merely economic in its
nature."
Once it is appreciated that the loss in respect of which the plaintiff in the
present case is suing is loss to his pocket, and not for physical damage to
the house or foundations, then most, if not all the difficulties surrounding
the limitation question fall away. The plaintiff's loss occurs when the market
value of the house is depreciated by reason of the defective foundations, and
not before. If he resells the house at full value before the defect is
discovered, he has suffered no loss. Thus in the common case the occurrence of
the loss and the discovery of the loss will coincide.
But the plaintiff cannot postpone the start of the limitation period by
shutting his eyes to the obvious. In Dennis v. Charnwood Borough Council
[1983] Q.B. 409, 420, a case decided in the Court of Appeal before the Pirelli
case reached the House of Lords, Templeman L.J. said that time would begin to
run in favour of a local authority:
"if the building suffers damage or an event occurs which reveals the
breach of duty by the local authority or which would cause a prudent
owner-occupier to make investigations which, if properly carried out, would
reveal the breach of duty by that local authority."
In other words, the cause of action accrues when the cracks become so bad, or
the defects so obvious, that any reasonable homeowner would call in an expert.
Since the defects would then be obvious to a potential buyer, or his expert,
that marks the moment when the market value of the building is depreciated,
and therefore the moment when the economic loss occurs. Their Lordships do not
think it is possible to define the moment more accurately. The measure of the
loss will then be the cost of repairs, if it is reasonable to repair, or the
depreciation in the market value if it is not: see Ruxley Electronics and
Construction Ltd. v. Forsyth [1996] 1 A.C. 344.
This approach avoids almost all the practical and theoretical difficulties
to which the academic commentators have drawn attention, and which led to the
rejection of the Pirelli decision [1983] 2 A.C. 1 by the Supreme Court of
Canada in the Kamloops case, 10 D.L.R. (4th) 641. The approach is consistent
with the underlying principle that a cause of action accrues when, but not
before, all the elements necessary to support the plaintiff's claim are in
existence. For in the case of a latent defect in a building the element of
loss or damage which is necessary to support a claim for economic loss in tort
does not exist so long as the market value of the house is unaffected. Whether
or not it is right to describe an undiscoverable crack as damage, it
clearly cannot affect the value of the building on the market. The existence
of such a crack is thus irrelevant to the cause of action. It follows that the
judge applied the right test in law.
Their Lordships repeat that their advice on the limitation point is confined
to the problem created by latent defects in buildings. They abstain, as did
Cooke P., from considering whether the 'reasonable discoverability' test
should be of more general application in the law of tort.
It is regrettable that there should be any divergence between English and
New Zealand law on a point of fundamental principle. Whether the Pirelli case
[1983] 2 A.C. 1 should still be regarded as good law in England is not for
their Lordships to say. What is clear is that it is not good law in New
Zealand.
There is no ground for disturbing the judge's conclusions on the facts, as
to which there are in any event concurrent findings.
Finally their Lordships would wish to pay tribute to the excellence of all
three arguments at the bar and are particularly grateful for the learned and
comprehensive written submissions furnished by Miss French, to which they are
much indebted.
Their Lordships will humbly advise Her Majesty that the appeal should be
dismissed. By agreement, there will be no order as to costs.
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