PRODUCTS LIABILITY 135

direct relationship with him. The product was a dangerous one
even if only the proper percentage (4 per cent.) of acid had
been present, so that an unusual standard of care was required
and the distributors on this further ground owed a duty to take
care towards the plaintiff, and were in breach of that duty.

Manufacturers' Duty to Warn

The facts were different in another hair-dye case—Holmes
v. Ashford &: Others (supra), for the hair dye was delivered to
the hairdresser in labelled bottles together with a brochure of
instructions and both the labels and the brochure contained a
warning that the dye might be dangerous to certain skins; hence,
a test before use was recommended. The hairdresser had read
the labels and the brochure and was aware of the danger, but
he had made no test and did not warn the plaintiff. The plain-
tiff claimed damages against the hairdresser and the manufac-
turers, and was awarded judgment against both. On appeal by
the manufacturers, it was held that a manufacturer who puts a
dangerous article on the market must take reasonable steps to
prevent any person coming into contact with it from being
injured, as noted above, but it is not necessary in every case
that precautions should be taken to ensure that the ultimate
recipient of the article is warned of the danger. The manufac-
turers had given the hairdresser a warning which was sufficient
to intimate to him the potential danger of the dye and it was
not necessary that they should have warned the plaintiff.

In Farr v. Butters Bros. 8c Co. (1932), 2 K.B. 606, the defen-
dants were crane manufacturers, and they sold a crane in parts
to X 8c Co., a firm of builders; the parts were to be assembled
by X 8c Co/s men. The plaintiff, one of their employees, was
an experienced crane erector, and he discovered defects which
he marked with chalk. He said that he would report this to
X 8c Co., but he nevertheless worked the crane before the defects
had been remedied. Part of the crane fell and killed the man
concerned. It was held that the defendants were not liable
because there had been an opportunity of reasonable inspection;
hence, the defendants owed no duty to the deceased. It was
therefore useless to consider contributory negligence on the part
of the deceased.

Dangerous Articles Sold to Children

There have been cases where dangerous articles have been
sold to children. In Burfitt v. A. 8c E. Kille (1939), 2 All E.R.
372, a boy aged 12 bought a pistol for firing blank cartridges.