Beard v London General Omnibus Co

X, a bus conductor, decided to turn D’s bus around so that it was facing the right direction for the next journey, in the absence of the driver, and negligently hit P, who sued D. CA dismissed P’s claim since X had not been authorised to drive the bus and the negligence did not therefore occur within the scope of X’s employment. 

 

Smith LJ: Normally there is a presumption that the person operating the thing is authorised to do so, but this presumption is negatived here since it was the conductor, not the driver, who was driving.