HOW LIABILITY IS DETERMINED FOR
NEGLIGENCE
DUTY OF
CARE
STANDARD
OF CARE
LAW OF TORT
CAUSATION
HSKHAIRA
CAUSATION
WHETHER THE DEFENDANT'S ACT OR OMISSION
WAS THE CAUSE OF THE PLAINTIFF'S INJURIES OR
HARM SUFFERED?
LAW OF TORT
SIMPLE TEST DEVELOPED TO DETERMINE
CAUSATION IS THE "BUT FOR" TEST
QUESTION FOR THE TEST:
BUT FOR THE DEFENDANT'S ACTIONS OR
OMISSIONS, WOULD THE PLAINTIFF HAVE
SUFFERED DAMAGE?
ONUS OF PROVING THIS IS ON THE PLAINTIFF
HSKHAIRA
BARNETT v CHELSEA HOSPITAL
FACTS: P's HUSBAND BECOME ILL AFTER DRINKING
SOME TEA - WENT TO THE DEFENDANT HOSPITAL
BUT DOCTOR ON CALL WAS HIMSELF NOT WELL &
ASKED THE NURSE TO TELL HIM TO GO HOME AND
SEE HIS OWN DOCTOR - THE MAN WAS IN FACT
SUFFERING ARSENIC POISONING & DIED
LAW OF TORT
HELD: HOSPITAL OWED A DUTY OF CARE AND WAS IN
BREACH OF THE STANDARD OF CARE BUT - IT WAS NOT
LIABLE AS P DID NOT PROVE THAT BUT FOR THE HOSPITAL'S
NEGLIGENCE HER HUSBAND WOULD NOT HAVE DIED
HSKHAIRA
IMPORTANT TO NOTE THAT THE HIGH COURT IN
AUSTRALIA HAS EMPHASISED THAT THE BUT FOR TEST
IS NOT AN EXCLUSIVE TEST FOR CAUSATION. OTHER
TEST MAY ALSO BE USED. E.g. WHETHER THE
DEFENDANT’S ACTS OR OMISSIONS CAUSED OR
MATERIALLY CONTRIBUTED TO THE PLAINTIFF’S LOSS,
DAMAGE OR INJURY
SEE ALSO L-4-130; GF-P.137
LAW OF TORT
CORK v KIRBY MCLEAN LTD
YATES v JONES
LINDEMAN v COLVIN
HSKHAIRA
CIVIL LIABILITY REFORM LAW
CIVIL LIABILITY REFORM LAWS HAVE MODIFIED
‘CAUSATION’ AND NOW PROVIDE THAT TESTS
SHOULD BE:
IF DEFENDANT HAD ACTED CAREFULLY WOULD
PLAINTIFF HAVE SUFFERED HARM?
LAW OF TORT
AND
IS IT APPROPRIATE FOR THE LIABILITY TO EXTEND
TO THE HARM?
HSKHAIRA
HOW LIABILITY IS DETERMINED FOR
NEGLIGENCE
LAW OF TORT
DUTY OF
CARE
UNREALISTIC TO HOLD THE
DEFENDANT LIABLE FOR A
NEVER-ENDING CHAIN OF
EVENTS - THEREFORE
LIABILITY IS LIMITED BY THE
REMOTENESS OF DAMAGE
TEST
STANDARD
OF CARE
CAUSATION
REMOTENESS
OF DAMAGE
HSKHAIRA
WAGON MOUND NO:1
L-4-140; GF-p.140
CALTEX
REFINERY
LAW OF TORT
DOCKS
WAGON MOUND
OIL
HSKHAIRA
WAGON MOUND NO:1
LAW OF TORT
TEST: DAMAGE MUST BE OF A TYPE THAT A
REASONABLE PERSON WOULD HAVE FORESEEN AND
IT DOES NOT MATTER THAT THE EXTENT OF
DAMAGE WAS NOT FORESEEABLE
If YES - liable for that
TYPE or KIND of
reasonably foreseeable
damage and EXTENT
or AMOUNT of
damage is immaterial
HSKHAIRA
If YES - liable for that
TYPE or KIND of
reasonably foreseeable
damage and EXTENT
or AMOUNT of
damage is immaterial
LAW OF TORT
DISCUSSED IN WAGON MOUND NO: 2
IF THERE WAS A REAL AND NOT A
FAR-FETCHED RISK OF DAMAGE AND
IT COULD BE ELIMINATED WITHOUT
ANY DIFFICULTY, DISADVANTAGE OR
EXPENSE THE DEFENDANT WOULD
BE LIABLE
What is
reasonably
foreseeable?
HSKHAIRA
OTHER RULES THAT MAY
AFFECT DAMAGES
“THIN-SKULLED” OR “EGGSHELL” RULE.
LAW OF TORT
YOU MUST TAKE YOUR VICTIM AS
YOU FIND HIM/HER
WOULD THIS RULE CONTRADICT THE
REMOTENESS OF DAMAGE RULE AS
PROPOUNDED IN WAGON MOUND NOS: 1 & 2?
HSKHAIRA
SMITH v LEECH BRAIN & CO LTD
LAW OF TORT
FACTS: PLAINTIFF'S HUSBAND WAS A CRANE
DRIVER AND SUFFERED A BURNT LIP FROM SOME
MOLTEN METAL AT WORK. IT TURNED CANCEROUS
AS HE HAD A SUSCEPTIBILITY TO CANCER - HE DIED
HELD: THE BURN WAS A FORESEEABLE
CONSEQUENCE OF THE DEFENDANT’S NEGLIGENCE.
THE DEFENDANT WAS LIABLE EVEN THOUGH THE
DEATH, IN ITSELF, WAS NOT A REASONABLY
FORESEEABLE CONSEQUENCE.
HSKHAIRA
SMITH v LEECH BRAIN & CO LTD
LAW OF TORT
IT DID NOT CONTRADICT THE "THIN
SKULL” RULE - ONLY TYPE OF DAMAGES
MUST BE FORESEEABLE NOT EXTENT
TEST HERE WAS NOT WHETHER THE
BURNS WOULD CAUSE CANCER BUT
WHETHER THE NEGLIGENT ACT WOULD
CAUSE BURNS? CONSEQUENCES WERE
IMMATERIAL TO DETERMINE LIABILITY
HSKHAIRA
SMITH v LEECH BRAIN & CO LTD
ACCORDING TO WAGON
MOUND NO:1
YES - the TYPE or KIND of
harm (i.e. burns) was
reasonably foreseeable
LAW OF TORT
AS DISCUSSED IN WAGON
MOUND NO: 2
DEATH WAS CAUSED
BECAUSE VICTIM
HAD A
SUSCEPTIBILITY TO
CANCER
THERE WAS A REAL AND
NOT A FAR-FETCHED RISK
OF BURNS BEING CAUSED
BY THE NEGLIGENT ACT
What is
reasonably
foreseeable?
EXTENT OF DAMAGE IMMATERIAL
& THIN SKULL RULE APPLIED:
YOU TAKE YOUR VICTIMS AS YOU
FIND THEM
HSKHAIRA
OTHER RULES THAT MAY AFFECT
DAMAGES
NOVUS ACTUS INTERVENIENS
LAW OF TORT
WHERE A NEW INTERVENING ACT TAKES
PLACE AFTER THE DEFENDANT’S NEGLIGENCE
AND IS THE “PROXIMATE” OR “ACTUAL”
CAUSE OF THE PLAINTIFF’S DAMAGE
HSKHAIRA
HOW LIABILITY IS DETERMINED FOR
NEGLIGENCE
DUTY OF
CARE
STANDARD
OF CARE
LAW OF TORT
CAUSATION
DEFENCES
REMOTENESS
OF DAMAGE
HSKHAIRA
DEFENCES
ONCE A PRIMA FACIE CASE HAS BEEN
ESTABLISHED THE DEFENDANT CAN STILL
RESIST, REBUT OR REDUCE LIABILITY BY
RELYING ON A NUMBER OF DEFENCES
LAW OF TORT
VOLENTI NON FIT INJURIA VOLUNTARY ASSUMPTION OF RISK
CONTRIBUTORY NEGLIGENCE
HSKHAIRA
VOLENTI NON FIT INJURIA VOLUNTARY ASSUMPTION OF RISK
L-4-170; GF-p.142
LAW OF TORT
TO BE EFFECTIVE THE CONSENT MUST BE
TO THE FULL RISK AND MERE KNOWLEDGE
OF THE RISK IS INSUFFICIENT
IT IS A TOTAL DEFENCE AND THE PLAINTIFF
WILL GET NOTHING IF IT IS SUCCESSFULLY
ESTABLISHED BY THE DEFENDANT
HSKHAIRA
SMITH v BAKER & SONS
LAW OF TORT
FACTS: P EMPLOYED BY D AS A
BUILDING WORKER. HE WORKED IN A
PLACE WHERE, OCCASIONALLY, A
CRANE LIFTED ROCKS & STONES OVER
HIS HEAD. HE WAS AWARE OF THE RISK
POSED - A ROCK FELL & INJURED HIM
HELD: THE MERE FACT THAT P HAD FULL
KNOWLEDGE AND UNDERSTANDING OF THE RISK
DID NOT PRECLUDE HIM FROM RECOVERING THE
DAMAGES - TO SUCCESSFULLY RAISE THE DEFENCE
OF VOLUNTI NON FIT INJURIA D MUST SHOW THAT P
CONSENTED TO THE RISK.
HSKHAIRA
O'SHEA v PERMANENT TRUSTEE CO. OF NSW LTD
LAW OF TORT
FACTS: P WAS A PASSENGER IN A CAR DRIVEN BY F
THE INSURED OF D - BOTH P & F HAD BEEN
DRINKING - F HAD BLOOD ALCOHOL LEVEL OF 0.15 P HAD NOT BEEN WITH F THROUGHOUT THE
EVENING & DID NOT KNOW HOW MUCH HE HAD
HAD TO DRINK.
HELD: P HAD A PERCEPTION OF THE DANGER BUT
THAT DOES NOT ESTABLISH VOLUNTI FOR THERE
MUST BE FULL COMPREHENSION OF ITS EXTENT WHICH WAS NOT ESTABLISH BY THE FACTS. P WAS
25 % TO BE BLAMED.
HSKHAIRA
CONTRIBUTORY NEGLIGENCE
L-4-160; GF-p.141
AT COMMON LAW NO DAMAGES WERE PAYABLE IF
CONTRIBUTORY NEGLIGENCE WAS ESTABLISHED
LAW OF TORT
CRITICISMS OF THE RULE RESULTED IN THE
PASSING IN THE UK OF THE LAW REFORM
(CONTRIBUTORY NEGLIGENCE) ACT 1945 WHICH WAS
ESSENTIALLY FOLLOWED IN W.A. BY THE LAW
REFORM (CONTRIBUTORY NEGLIGENCE AND
TORTFEASORS' CONTRIBUTION) ACT IN 1947
ACT ESSENTIALLY PROVIDES THAT DAMAGES CAN
NOW BE APPORTIONED TAKING INTO ACCOUNT THE
DEGREE OF CONTRIBUTORY NEGLIGENCE OF THE
PLAINTIFF
HSKHAIRA
LAW OF TORT
LIABILITY FOR PURE
ECONOMIC LOSS FOR
NEGLIGENT MISSTATEMENTS
AND NEGLIGENT ACTS
HSKHAIRA
PURE ECONOMIC LOSS FOR
LAW OF TORT
YOU WILL PASS BUS165!
HSKHAIRA
HOW LIABILITY IS DETERMINED FOR
NEGLIGENT MISSTATEMENT
LAW OF TORT
DUTY OF
CARE
FOR GENERAL
NEGLIGENCE A LEGAL
RELATIONSHIP OR
OBLIGATION MUST BE
ESTABLISHED
FOR NEGLIGENT
MISSTATEMENT A
“SPECIAL”
RELATIONSHIP OR
OBLIGATION MUST BE
ESTABLISHED
HSKHAIRA
NEGLIGENT MISSTATEMENTS
HEDLEY BYRNE v HELLER
L-4-240; GF-p.164
LAW OF TORT
HELD: THERE COULD BE A DUTY OF CARE WITH
RESPECT TO NEGLIGENT MISSTATEMENT BUT IT
WAS NOT TO BE AS WIDE AS THE "FORESIGHT" TEST
USED FOR NEGLIGENT ACTS
FOR NEGLIGENT MISSTATEMENTS - DUTY OF CARE
ONLY AROSE IF THERE WAS A "SPECIAL
RELATIONSHIP" BETWEEN THE INQUIRER AND
MAKER OF THE STATEMENT
HSKHAIRA
NEGLIGENT MISSTATEMENTS
THIS SPECIAL RELATIONSHIP EXISTED ONLY WHEN:-
•THE INQUIRER TRUSTED THE MAKER TO TAKE SUCH
DEGREE OF CARE AS THE CIRCUMSTANCES REQUIRED
•IT WAS REASONABLE FOR THE INQUIRER TO TRUST THE
LAW OF TORT
MAKER
•MAKER GAVE THE ADVICE KNOWING OF THE TRUST
•ADVICE GIVEN IN RESPONSE TO A SPECIFIC ENQUIRY
•INFORMATION USED FOR THE PURPOSE OF THE ENQUIRY
•NO DISCLAIMER OF RESPONSIBILITY
HSKHAIRA
LIMITED TO A
“SPECIAL”
RELATIONSHIP
LAW OF TORT
LIMITED TO A
RELATIONSHIP
NEGLIGENT MISSTATEMENTS
THERE WILL BE
ADDITIONAL
REQUIREMENTS
TO ESTABLISH A
DUTY OF CARE
HSKHAIRA
LAW OF TORT
NEGLIGENT MISSTATEMENTS
IS THIS DUTY OWED ONLY BY
PERSONS WHOSE BUSINESS IT IS
TO GIVE ADVICE OR DOES
EVERYONE WHO GIVES
INFORMATION HAVE AN
OBLIGATION TO BE CAREFUL?
HSKHAIRA
NEGLIGENT MISSTATEMENTS
LAW OF TORT
L SHADDOCK & ASSOCIATES PTY LTD v PARRAMATTA CITY COUNCIL
L-4-260; GF-p.165
Facts:
Purchasers, before buying the property
in question for redevelopment, had inquired from
the Municipal Council if property was proposed to
be affected by any road widening or re-alignment
proposals. In the certificate issued by the Council it
failed to disclose that the land would be subject to
road widening. In reliance on the certificate the
purchasers bought the property.
HSKHAIRA
LAW OF TORT
NEGLIGENT MISSTATEMENTS
HELD:
THE PERSON
GIVING INFORMATION TO
ANOTHER WHOM S/HE
KNOWS WILL RELY UPON
IT IN CIRCUMSTANCES IN
WHICH IT IS REASONABLE
TO DO SO, IS UNDER A
DUTY TO EXERCISE
REASONABLE CARE THAT
THE INFORMATION GIVEN
IS CORRECT
HSKHAIRA
NEGLIGENT MISSTATEMENTS
SHADDOCK'S CASE IN FACT APPROVED THE
MINORITY VIEW IN MLC v EVATT [L-4-260; GF-p.165]
LAW OF TORT
MINORITY IN M.L.C. v EVATT HELD THAT IF
THE INFORMATION WAS GIVEN AS PART OF A
BUSINESS ARRANGEMENT THERE MAY BE A DUTY
OF CARE REGARDLESS OF WHETHER IT IS THE
BUSINESS OF THE DEFENDANT TO GIVE ADVICE
HSKHAIRA
NEGLIGENT MISSTATEMENTS
THE FOLLOWING TESTS MUST BE APPLIED TO DETERMINE
DUTY OF CARE:
•SPEAKER MUST OR OUGHT TO REALISE THAT S/HE IS BEING
TRUSTED BY THE RECIPIENT FOR THE ADVICE
•SUBJECT MATTER MUST BE OF A SERIOUS OR BUSINESS
NATURE
•SPEAKER MUST OR OUGHT TO REALISE THAT RECIPIENT
LAW OF TORT
INTENDS TO ACT ON THE ADVICE/INFORMATION GIVEN
•IT IS REASONABLE IN ALL THE CIRCUMSTANCES FOR THE
RECIPIENT TO SEEK/ACCEPT/RELY ON THE UTTERANCE OF
THE SPEAKER
HSKHAIRA
NEGLIGENT MISSTATEMENTS
LAW OF TORT
THE TORT OF NEGLIGENT
MISSTATEMENT DEFINITELY
EXISTS AND A PERSON WHO MAKES
A STATEMENT DIRECTLY OR
INDIRECTLY TO ANOTHER, IN
CIRCUMSTANCES WHERE S/HE
KNOWS, OR SHOULD KNOW, THAT IT
WILL BE RELIED UPON OWES A
DUTY OF CARE TO THAT OTHER
PERSON.
HSKHAIRA
DUTY OF CARE
DONOGHUE
v
STEVENSON
LAW OF TORT
BASED ON THE
NEIGHBOUR
PRINCIPLE:
PROXIMITY +
REASONABLE
FORESIGHT
HEDLEY
BYRNE
v
HELLER &
PARTNERS
THE MAKER OF
THE STATEMENT
IS TRUSTED AND
THERE IS
RELIANCE UPON
THAT
STATEMENT
SHADDOCK
v
PARRAMMATTA
CITY COUNCIL
ANYONE WHO
GIVES SERIOUS
OR BUSINESS
ADVICE IN
CIRCUMSTANCES
WHERE IT MAY
BE RELIED UPON
IS LIABLE
HSKHAIRA
LAW OF TORT
PURE ECONOMIC LOSS FOR
HSKHAIRA
CALTEX OIL (AUST) PTY LTD v THE DREDGE “WILLEMSTAD
L-4-215
LAW OF TORT
FACTS: A PIPELINE OWNED BY A THIRD-PARTY WAS
DAMAGED BY THE DEFENDANT’S NEGLIGENT HANDLING
OF THE DREDGE “WILLEMSTAD”. THE OIL WAS NEEDED
BY PLAINTIFF WHO HAD TO TRANSPORT THE OIL BY
ALTERNATIVE MEANS AT A CONSIDERABLE EXPENSE.
HELD: CALTEX OIL COULD RECOVER THE ECONOMIC
LOSS SUFFERED EVEN THOUGH THERE HAS BEEN NO
PERSONAL INJURY OR DAMAGE TO THE PLAINTIFF’S
PROPERTY. A CLAIM SUCH AS THIS CAN ONLY BE MADE
WHERE THE DEFENDANT KNOWS OR OUGHT TO KNOW
THAT A SPECIFIED PERSON IS LIKELY TO SUFFER LOSS IF
S/HE IS NEGLIGENT.
HSKHAIRA
JUNIOR BOOKS LTD v VEITCHI CO LTD
L-4-215
LAW OF TORT
FACTS: THE DEFENDANTS LAID A DEFECTIVE FLOOR IN
THE PLAINTIFF’S FACTORY WHICH CRACKED A COUPLE
OF YEARS LATER. THE COST OF REPLACEMENT OF THE
ENTIRE FLOOR OF £200,00 WAS CLAIMED
HELD: ALTHOUGH THERE WAS NO PHYSICAL INJURY
SUFFERED THE DEFENDANT FLOORLAYERS WERE
LIABLE FOR THE ECONOMIC LOSS OF £200,00 + ANY
CONSEQUENTIAL LOSS OF PROFITS DURING THE PERIOD
THAT THE BUSINESS WOULD BE CLOSED FOR THE
RELAYING OF THE FLOOR.
HSKHAIRA
HAWKINS v CLAYTON
L-4-215
FACTS: THE DEFENDANT SOLICITORS HAD DRAFTED
THE WILL OF THE DECEASED BUT FAILED TO INFORM
THE EXECUTOR (WHO WAS ALSO THE PRINCIPAL
BENEFICIARY) OF THE WILL UNTIL SIX YEARS LATER.
THE HOUSE LEFT TO THE PLAINTIFF HAD BECOME
RUNDOWN AND MOST OF THE FURNITURE STOLEN
LAW OF TORT
HELD: ALTHOUGH THERE WAS NO PHYSICAL INJURY
SUFFERED THE DEFENDANTS WERE LIABLE FOR THE
ECONOMIC LOSS SUSTAINED BY THE PLAINTIFF
NOTE: A BARRISTER IS PROTECTED BY LEGAL
IMMUNITY FOR ANY WORK DONE IN COURT
HSKHAIRA
LAW OF TORT
END OF LECTURES
ON LAW OF TORTS
HSKHAIRA
HOW TO ESTABLISH LIABILITY UNDER THE GENERAL LAW OF
NEGLIGENCE
IS THERE A DUTY OF CARE OWED?
Is there a legally recognised relationship between the plaintiff
and the defendant that brings them within the "neighbour
principle" discussed in Donogue v Stevenson?
LAW OF TORT
Here discuss briefly the facts of Donogue v Stevenson and the
statement mentioning the "neighbour principle"
Explain too that the scope of the "neighbour principle" is
limited by the test of proximity which in turn depends on the test
of reasonable foresight.
HSKHAIRA
HOW TO ESTABLISH LIABILITY UNDER THE GENERAL LAW OF
NEGLIGENCE
HAS THE STANDARD OF CARE BEEN BREACHED?
Standard of care is measured according to the standard that
would be observed by a reasonable person.
LAW OF TORT
Standard is not an absolute standard to take care against all
risks (discuss Glasgow Corp. v Muir) but only against those that
are highly probable; possible; or where there is a material risk.
Does not include damage that may be foreseeable but is highly
improbable (discuss Bolton v Stone).
Standard is also dependent on other attributes of the plaintiff
[see Paris v Stephen Borough Council L-4-100]
HSKHAIRA
HOW TO ESTABLISH LIABILITY UNDER THE GENERAL LAW OF
NEGLIGENCE
HAS DAMAGE RESULTED FROM THE BREACH OF THE
STANDARD OF CARE?
LAW OF TORT
Prove that there was causation - a connection between
the breach in the standard of care and the damage
suffered.
Test used is the "but for" test. Discuss Barnett v
Chelsea Hospital or Cork v Kirby MacLean Ltd or
Yates v Jones.
HSKHAIRA
HOW TO ESTABLISH LIABILITY UNDER THE GENERAL LAW OF
NEGLIGENCE
IS THE DAMAGE SUFFERED TOO REMOTE?
LAW OF TORT
Here discuss that according to Wagon Mound No:1
only type/kind of damage that is reasonably
foreseeable will be allowed.
The degree of foreseeability of that type/kind of
damage is limited by Wagon Mound No: 2 which states
that the risk of damage should be real and not far
fetched and could have been avoided by a reasonable
person without too much expense or effort.
HSKHAIRA
HOW TO ESTABLISH LIABILITY UNDER THE GENERAL LAW OF
NEGLIGENCE
ARE THERE ANY DEFENCES AVAILABLE TO THE
DEFENDANT?
LAW OF TORT
Here discuss such defences as contributory
negligence and volunti non fit injuria if
applicable.
HSKHAIRA
SOME ADVICE
LAW OF TORT
PLEASE READ THE
INSTRUCTIONS
CAREFULLY
NO REFERENCING
REQUIRED IN EXAMS
HSKHAIRA
AUTHORITIES SHOULD NOT BE
MERELY CITED BUT DISCUSSED
LAW OF TORT
The case example here is Carlill v Carbolic
Smoke Ball Co. case
The case applicable here is Carlill v Carbolic
Smoke Ball Co. case where a lady
responded to an advertisement in a
newspaper which stated that if any person
were to take the smoke ball over a fixed
period of time they would be cured of the
flu. To show their sincerity in this matter
the advertisers deposited £100 in a bank.
The court held that in this case ................
HSKHAIRA
•Make firm reasonable presumptions based on the
facts of a problem and not all possible assumptions
•Make firm conclusions
•Names of cases cited should be either highlighted or
underlined
•Start each new point/argument on a new
paragraph
LAW OF TORT
•Every new section and question should be started
on a new page
•Do not discuss non-issues - confine yourself to the
issues - do not discuss the obvious
HSKHAIRA
REMEMBER
Examiners will be looking for
•ISSUES, whether legal concepts introduced have
been defined/explained
•LEGAL ARGUMENTS,
•LEGAL AUTHORITIES in support of those
LAW OF TORT
arguments
•FIRM CONCLUSIONS
HSKHAIRA
LAW OF TORT
TORT LAW
General Negligence
Duty of Care
Standard of Care
Causation
Defences –
Contributory Negligence
Remoteness of Damages
HSKHAIRA
LAW OF TORT
Donoghue v Stevenson
Bolton v Stone
Wagon Mound I & II
Paris v Stephen Borough Council
Barnett v Chelsea Hospital
Glasgow Corp. v Muir
Nagle v Rottnest Island Authority
Mercer v Commissioner For Transport &
Tramways (NSW)
NOTE - LIST IS NOT EXHAUSTIVE!
HSKHAIRA
END OF
COMMERCIAL LAW
LECTURES FOR
THIS SEMESTER
LAW OF TORT
GOODBYE AND
GOOD LUCK
IN YOUR
EXAMINATIONS
HSKHAIRA