P bought pumps for keeping its lobsters alive from X, manufactured by D. They were faulty and the lobsters died. P sued D for causing pure economic loss. CA rejected this since, for pure economic loss, there has to be a special degree of proximity (i.e. a special relationship) + reliance + assumption of responsibility. There was not sufficient proximity between a purchaser and a manufacturer in pure economic loss cases.
Goff LJ: For pure economic loss, the purchaser can only sue the immediate vendor and not a manufacturer. Junior Books is distinguished as giving an exceptionally close relationships on its own facts. There was also reliance. Therefore it is not an authority for the proposition that the manufacturers or TPs are commonly liable for economic loss.
