Woods v Multi-sport Holdings Pty Ltd

This case concerned an appeal to the High Court of Australia following a decision of the Full Court of the Supreme Court of Western Australia, which had upheld a judgment in favour of the respondent, Multi-Sport Holdings Pty Ltd. The appellant, Mr Michael Woods, had suffered a severe eye injury while playing indoor cricket at Multi-Sport's premises. Mr Woods alleged that Multi-Sport had breached its duty of care by failing to provide him with a protective helmet and by failing to warn him of the specific risk of eye injury associated with playing indoor cricket.

The High Court was required to determine whether Multi-Sport had breached the duty of care owed to Mr Woods. Specifically, the court had to consider whether the failure to provide protective headgear and the absence of a warning about the particular dangers of eye injury constituted a breach of that duty. The court also had to assess the relevance of industry practice, the rules of the game, and the obviousness of the risk in determining whether Multi-Sport's conduct was reasonable in the circumstances.

The High Court, in a majority decision, found that Multi-Sport had breached its duty of care to Mr Woods in two respects: by not providing a protective helmet and by not warning him of the special risks of eye injury. The court reasoned that the reasonableness of an occupier's conduct in warning an entrant of a risk is a question of fact dependent on all circumstances, and the obviousness of a risk is only one factor. The court did not consider the risk of serious eye injury in indoor cricket to be so obvious as to negate the need for a warning or the provision of protective equipment.

The appeal was dismissed with costs.