Simms v Leigh RFC

P was playing rugby at D’s ground and was tackled, hurling him into a concrete wall close to the touchline so that his leg broke. Wrangham J held that although D had a duty of care to P, the likelihood of injury was so remote that D would not be liable. E.g. it had never happened before and only resulted as a collision of 3 players. He says that a player “willingly accepts all the risks of playing a game on such a playing field as complies with the byelaws laid down by the governing body of the game.” Therefore P has to fail.