Re Polemis [1921]

Since 1850, two competing views of
remoteness test:
1.  Consequences
are too remote if a reasonable man would not have foreseen them.
2.  If
a reasonable man would have foreseen any
to plaintiff as likely to result from his act, then he is liable for
direct consequences of his act suffered by plaintiff, whether a reasonable man
would have foreseen them or not.
In this case, Court of Appeal apparently settled English
law in favour of second rule.
Stevedores negligently dropped plank into hold of
ship, where benzene had leaked.
Resulting fire destroyed ship.
Charterers, employers of stevedores, were
held responsible for all the direct consequences of the negligence, even though
they could not reasonably have been anticipated.