Law digests: 8 October 2021

Abuse

Blackpool Football Club Ltd v DSN [2021] EWCA Civ 1352, [2021] All ER (D) 33 (Sep)

The appellant football club, Blackpool FC, appealed against a decision that it was vicariously liable for the acts of FR, a talent scout, when he had sexually abused the respondent, DSN, then aged 13, while on a trip to New Zealand organised by FR in 1987 (see [2020] All ER (D) 92 (Mar)). The Court of Appeal, Civil Division, in allowing the appeal on the vicarious liability grounds, held, among other things, that: (i) the evidence as identified by the judge had not justified a finding that the relationship between Blackpool FC and FR was one that could properly be treated as akin to employment. However, on the limitation grounds concerning the disapplication of the applicable primary limitation period pursuant to s 33 of the Limitation Act 1980, the court held that the judge had been entitled to conclude that no real risk of substantial or significant prejudice had been caused to Blackpool FC