1069 - 1562

Salmonella Poisoning - Causation and Quantum

Reynard v Exquisite Quisine Limited t/a Latours Cuisine - Court of Session 9 November 2005

Mrs. Reynard, formerly a midwife by profession, acquired salmonella poisoning after eating a meal at a Chinese restaurant. The Restaurant admitted liability for the salmonella infection, which in turn caused Mrs. Reynard to develop reactive arthritis. The Restaurant disputed both the extent to which Mrs. Reynard had been affected by the reactive arthritis and the value of her claim.

Lord Hodge preferred Mrs. Reynard's expert evidence that she continued to suffer from the reactive arthritis which was responsible for her ongoing disability, rather than her other health problems. He found that her ruptured Achilles tendons which occurred 18 months after the poisoning were, on a balance of probabilities, materially contributed to by the reactive arthritis. He was not satisfied, on a balance of probabilities that Mrs. Reynard suffered from a psychological condition unrelated to the reactive arthritis, despite a number of serious family problems and health problems, both physical and psychological prior to the salmonella poisoning. He further found that her pre-incident weight and blood pressure problems would not have compromised her career and that her weight problem had been materially exacerbated by the reactive arthritis, which in turn was causally linked to both the par aesthesia in her thigh and bilateral dry eye.

Lord Hodge awarded £1.2 million in damages of which £85,000 related to pain and suffering, £385,380 to future wage loss, £218,000 to future care and £146,250 to additional care on deterioration of her health.

Lord Hodge clearly preferred Mrs. Reynard's medical evidence and in particular the evidence of two of her treating doctors who had cared for her over a period of time. He rejected a motion by the defence to allow a surveillance video of Mrs. Reynard which had been obtained between the initial hearing and continued hearing, and a report by a histopathologist, to be admitted as evidence, on the basis that it would not be fair or in the interests of justice. He was of the view that no acceptable reason had been given as to why this evidence came so late in the day and the delay and inconvenience which would be caused in admitting it were not justifiable.

It is therefore unknown whether the admission of this evidence would have had any bearing on the damages awarded. The case does however serve as a reminder that all evidence parties intend to rely upon should be obtained and lodged on time or parties run the risk of not being able to rely on the evidence at all.

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