to impose liability. In reintroducing the need for proximity as a central control device, it has been stated that these three stages are 'ingredients' of liability, rather than tests in their own right. For example, liability can arise between complete strangers, where positive acts involving foreseeable physical harm occur; where negligent omissions and misstatements occur however, it is necessary to show a proximate relationship, as well as a foreseeability of harm. Status of the claimant The status of the claimant in an act of negligence can result in a duty of care arising where it would not normally – as is the case with rescuers – or prevent a duty of care existing altogether. Claims that a doctor may owe a mother a duty of care to advise against child birth, and claims that police may owe an individual involved in criminal behavior a duty of care, have been barred. In McKay v Essex Area Health Authority, a child's claim that a doctor should have advised his mother to seek an abortion was struck out; Whilst the Congenital Disabilities (Civil Liability) Act allows a course of action where negligence is the cause of a disability, wrongful life has remained barred for policy reasons. Similarly, where a criminal attempted to escape police capture in Vellino v Chief Constable of the Greater Manchester Police, his claim that they owed him a duty of care not to let him escape after they had arrested him was branded 'absurd'. Rescuers It has been established at common law that those who attempt rescue are owed a duty of care by those who create dangerous situations, in which it is foreseeable rescuers may intervene. This duty can apply to professional rescuers – such as doctors or lifeguards – as much as ordinary individuals, and may even apply where the rescuer engages in a careless or reckless rescue attempt. The basis for this liability was first recognised in Haynes v Harwood. Here, a child who threw a stone at a horse, causing it to bolt, was liable to a policeman who attempted to stop it subsequently, and was injured. The duty was confirmed in the later case of Baker v T E Hopkins & Son Ltd, with Wilmer LJ stating that: Assuming the rescuer not to have acted unreasonably, therefore, it seems to me that he must normally belong to the class of persons who ought to