(c) There are two categories of economic/financial loss, which may form the basis of a claim in negligence. First, there is economic loss arising out of physical injury or damage to property; and, secondly, there is what is known as ‘pure’ economic loss, which is the sole loss sustained, unconnected with physical damage (Spartan Steel and Alloys Ltd v Martin and Co (1973)). Only the former is now recoverable, unless the claimant can show that there was a ‘special relationship’ between them and the defendant, in which the defendant assumed responsibility for the claimant’s economic welfare (Hedley Byrne & Co v Heller and Partners (1964) & Williams v Natural Life Health Foods Ltd (1998)). |