Beard v London General Omnibus Co. (1900)

Law of Torts · Vicarious Liability

Facts.

At the end of a journey, in the driver’s absence, the conductor of the defendants’ omnibus drove the bus in order to turn it round for the return journey. He drove negligently and injured the plaintiff.

Issue.

Is the master liable where the servant performs an act wholly outside the class of work for which he was engaged?

Held.

No. The conductor was employed to collect fares, not to drive. Driving was not a wrongful mode of doing his job; it was outside the sphere of his employment altogether.

Why it matters.

Read with Limpus, it fixes the boundary of the course of employment — and together the two cases answer the bus-conductor problem set repeatedly by .

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