Smoldon v Whitworth & Anor [1996] EWCA Civ 1225 (17th December, 1996)

Rugby referee found liable for injuries caused as a result of a scrum collapsing. The defendant had invited the judge to say that nothing short of reckless disregard for the claimant's safety would suffice to establish a breach of the duty which the referee admittedly owed to the player. The court, however, adopted the test derived from Condon that the duty was to exercise such degree of care as was appropriate in all the circumstances.