... judgments and policy decisions. It may be wrong however, to hold one responsible for all consequences of negligence. Sometimes, the outcome is freak or unusual and as such, it may not entirely be fair to put blame and accountability solely on the tortfeasor. Hence, the remoteness of damage that is the degree to which consequence of negligence and the type of consequence is anticipated from negligent conduct must be taken into account. Causation and remoteness are separate issues but they do tend to merge in practice. Lord Denning: 'The truth, all these terms - duty, causation and remoteness - are all devices by which the courts limit the range of liability...ultimately it is a question of policy for judges to decide' in Lamb v Camden London Borough Council [1981]. Causation - Claimant focus The 'but for' test - removing irrelevant causes If harm to the claimant would not have occurred 'but for' the defendant's negligence ...

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