Spartan Steel and Alloys Ltd v Martin & Co (Contractors) Ltd  1 QB 27 (CA)
The claimants manufactured stainless steel alloys at a factory 24 hours a day. The defendants’ employees, who were working on a nearby road, damaged the electrical supply cable to the factory. The electricity board shut off the power supply to the factory for 14½ hours until the cable was mended. The claimants scrapped a ‘melt’ in the furnace, reducing its value by £368. If the supply had not been cut off, they would have made a profit of £400 on the melt, and £1767 on another four melts, which would have been put into the furnace. They claimed damages from the defendants in respect of all three sums.
The claimants could recover the damage to the melt in progress and the loss of profit on that melt. They could not recover for the loss of profit during the time that the electricity was switched off. The damage to the melt in progress was physical damage and the loss of profit on it was a direct consequence of the physical damage. The further loss of profit was pure economic loss and not recoverable.
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