Muirhead v Industrial Tank Specialities [1986] QB 507

• Plaintiff bought pumps for keeping its lobsters alive from X, manufactured by Defendant. They were faulty and the lobsters died.

• Plaintiff sued Defendant 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 L

• 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. 

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