In The Wagon Mound (No. 1) [1961] A.C. 388, Viscount Simmonds expressed the hope that, by replacing directness (and its attendant “insoluble” problem, the search for breaks in the chain of causation) with reasonable foreseeability as the test for remoteness of damage in negligence, “the law will be simplified and . . . palpable injustice will be avoided”. Lawyers have long recognised that the first of these aspirations has failed dismally. Regrettably, the Court of Appeal decision in Jolley v. Sutton London Borough Council [1998] 1 W.L.R. 1546 provides a stark example of failure on both counts.