[2013] EWCA Civ 546
Where the character of a joint criminal enterprise was such that it was foreseeable that a party to the enterprise could be subject to unusual or increased risks of harm as a consequence of the pursuit of those criminal activities, any resulting injury could properly be said to be caused by the claimant's criminal act even if it resulted from the negligent or intentional act of another party to the illegal enterprise.
CA (Civ Div) (Elias LJ, Rafferty LJ, Ryder LJ)
17/05/2013