Smith v Littlewoods Organisation Ltd

Smith v Littlewoods Organisation Ltd [1987] UKHL 18 was a House of Lords case addressing negligence and duty of care. Littlewoods purchased a cinema in 1976, intending to demolish it for a supermarket. After initial work, they left the premises unattended, leading to vandalism and fires. On July 5, 1976, vandals caused a fire that destroyed the cinema and damaged nearby buildings.

Neighbors sued Littlewoods, claiming negligence due to inadequate security measures like regular inspections or guarding. The court initially found the fire foreseeable, but Littlewoods appealed, arguing lack of prior knowledge of fire attempts. The First Division of the Inner House allowed the appeal, leading to further review by the House of Lords.

The Lords dismissed the appeals, stating an empty cinema posed no inherent danger and that imposing a 24-hour guard would be unreasonable. They ruled mere foreseeability isn't sufficient for liability without a closer defendant-wrongdoer relationship. The case highlights the law's reluctance to impose general duties to prevent third-party wrongdoing, consistent with cases like Home Office v Dorset Yacht Co.