there is ‘little historical basis in Scots law for the kind of structural difficulties that have restricted English law' in the development of mechanisms to protect so-called 'rights of personality'. The actio iniuriarum heritage of Scots law gives the courts scope to recognise, and afford reparation in, cases in which no patrimonial (or 'quasi-patrimonial') 'loss' has occurred, but a recognised dignitary interest has nonetheless been invaded through the wrongful conduct of the defender. For such reparation to be offered, however, the non-patrimonial interest must be deliberately affronted: negligent interference with a non-patrimonial interest will not be sufficient to generate liability. An actio iniuriarum requires that the conduct of the defender be 'contumelious' - that is, it must show such hubristic disregard of the pursuer's recognised personality interest that an intention to affront (animus iniuriandi) might be imputed. Reparation for wrongdoing Reparation for negligence Overview In principle, only interests which may be 'damnified' are recognised as reparable under the principles of Aquilian liability and so in practice this means that harm done, through negligence, to non-patrimonial interests does not generate a right of reparation under the principles outlined below. With that said, since the end of the 18th century, it has been recognised that so-called 'personal injury' cases are in principle to be treated no differently from cases concerning damage done to patrimonial interests. Duty of care Donoghue v Stevenson (1932), also known as ‘The Paisley Snail case’, is considered to have defined the concept of duty of care. Mrs. Donoghue was in a cafe in Paisley where she consumed a bottle of ginger beer which contained a decomposing snail in an opaque bottle. The snail was invisible to the naked eye until the contents of the bottle had been almost completely consumed. Consequently, she suffered serious gastric problems. To whom do we owe a duty of care? Donoghue says that we owe this duty to our neighbours: “The rule that you are to love your neighbour becomes in law, you must not injure your neighbour; and the lawyer's question, Who is my neighbour? receives a restricted reply. You must take reasonable care to avoid acts or omissions which you can reasonably foresee would be likely to injure your neighbour. Who, then, in law, is my neighbour? The answer seems to be —persons who are so closely and directly affected by my act that I ought reasonably to have them in