China Navigation Co Ltd v Attorney General [1932] 2 KB 197

A British shipping company in Chinese waters claimed that the government had a duty to provide them with guards against pirates.

CA ruled that the government owed no duty to citizens in foreign parts and that if it chose to offer such security then it could do so on whatever terms it liked (e.g. demand that the subjects pay for the cost of the security).

The shipping firm had tried to argue that from the duty of the government to protect the country we can infer a duty to protect subjects everywhere (CA says no you can’t) and that British ships were really an extension of British dominions (CA says no they’re not)