Parsons v Uttley Ingham [1978]

Defendant supplied hopper for storing pig food, but
faulty.
Pig food went mouldy causing death of pigs.
Court of Appeal held loss of pigs not too remote, but reasoning differed.
Denning:
Are two tests for remoteness in contract.
One test for loss of profit – Heron II
One, less strict, test for physical damage – WM tort test.
Scarman & Orr:
Heron II test applies, but it is type and not extent
of damage that must be reasonably foreseen.
Plaintiff obviously could not contemplate 250 pigs
dying, but this irrelevant as illness of pigs was foreseeable.