... rescue, if a rescuer does so attempt, he is held to a certain standard of care. A rescuer would be held liable if they were to worsen the condition of the person they are attempting to rescue, or by their actions, prevent more qualified professionals from rescuing, as was the case in Zelenko v Gimbel Brothers (1935) 287 N.Y.S 134.6 In the past the United Kingdom has been reluctant to compensate a rescuer for injuries he may have suffered while attempting a rescue. 'In fact, occasionally the system not only displayed a reluctance to compensate the bystander injured in his attempt to help, but often refused to justify the intervention when the bystander inadvertently caused harm.'7The maxim's of voluntary assumption of risk and a new intervening action to deny the rescuer compensation was relied upon by the courts as way to avoid awarding compensation. The maxim for voluntary assumption of risk ...

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