Limpus v London General Omnibus Co. (1862)

Law of Torts · Vicarious Liability

Facts.

The defendants’ bus driver had printed instructions never to race with or obstruct other omnibuses. In disobedience of those instructions he drove across the road to obstruct a rival bus, causing a collision that damaged it.

Issue.

Is the master liable for an act expressly forbidden, where the servant was nonetheless doing the work he was employed to do?

Held.

Yes. The driver was employed to drive the bus, and racing was merely an improper manner of driving it. A prohibition on the way work is done does not take the servant outside the course of employment.

Why it matters.

It is the leading authority on the mode/sphere distinction, and the case that defeats the student instinct that “expressly forbidden” means the master escapes.

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