Lord Atkins in the case of Donoghue v. Stevenson was the first to extract and apply a general duty of care in the tort of Negligence because this was a general duty of care, a duty that could exist without a pre-existing contractual relationship. Therefore, the common law since the initial landmark case of Donoghue has attempted to form a principle, in what would be too wide a general principle, that can distinguish between situations that do and those that do not give rise to a duty of care. It is doubtless that there are many cases there has been a development of a coherent principle that can adequately identify situations in which a duty of care has arisen….(short extract)

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