Rugby Clubs and the “Duty of Care”

– Court Of Appeal considers the scope of the duty of care owed by a Rugby Club to rugby players

Barry Riley

A recent case decision which could be interesting reading for all the Rugby clubs out there . . .

Sutton v. Syston Rugby Football Club, CA, 20/10/11

The Claimant (the rugby player) was injured whilst training for rugby. His knee was hurt by a sharp object left behind by previous users, but almost hidden. He said that the Defendants (the club) were negligent in not having inspected the pitch before training.

The club appealed saying that whilst it could be expected to see objects on the surface, a more detailed inspection was not to be required. The RFU guidelines said it should be inspected.


The club’s appeal succeeded. A question of causation was a mixed one of fact and law. Here the court had been wrong to hold that there was a higher duty to inspect the touchdown areas. The grass had been lush, and a witness inspecting the area immediately after the accident had not located the object. A reasonable ‘walk-over’ inspection of the pitch beforehand would not have revealed it either.

As to the duty of care owed, the Court of Appeal held that a rugby club owed players a duty to conduct an inspection of the pitch pre-training session or match and which inspection should be carried out at a reasonable walking pace by a coach or match organiser.

However, on the facts/evidence, the Court of Appeal held that such reasonable inspection would not have revealed the defect.

For more information as to what we can do to assist your Rugby Club, call Barry Riley or Tony Forster on 0117 9453 042/040. Alternatively, contact us over email, and/or

For more detailed assistance with regards to Personal Injury matters, contact a member of our PI team, whose details can be found in the “Meet the Team” section of this blog.



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