education officers performing the authority’s functions with regard to children
with special educational needs.
but before Z v UK]
particular skill or profession, might owe a duty of care to particular pupils
where it could be foreseen that those pupils might be injured if due skill and
care were not exercised.
policy reasons for not imposing such a duty and should be slow to find
negligence since this might interfere with authority’s duties.
of decision – might mean that education authorities owe duty of care to
children, through teachers etc, to show reasonable care in their education.