3rd element

• There must be a sufficiently close connection between the employment and the employees conduct (the tort)
• Limpus v London


  Employer liable if acting against orders but still doing their job
• Rose v Plenty


  Employer liable if acting against orders but still doing their job
• Twine v Beans express

  Employer not liable if it's unauthorised and gains no benefit
• Beard v London general omnibus (1900)


  Employer not liable if something is outside employment
• Century insurance v NI road transport board


  Employer liable if employee does job negligently
• Hilton v Thomas Burton


  Employer not liable if employee is on a 'frolic' of their own
• Smith v Stages


  Employer liable if being paid during 'frolic'
• Lister v Hesley hall


  Introduced 'closed connection' test:

  Was the commission of the alleged tort 'closely connected' to the employment?
• Mattis v Pollock


  The assault was closely connected to employment
• Cox v Ministry of justice


  Organisation does not have to carry out commercial activity or make a profit, can still be held liable
• Mohamud v Morrison's


  What was the nature of the job?

  Was there a connection between this and the conduct?

  Not liable if no close connection
• Armes v Nottingham


  Is the role integral to the business?