situations in which the courts recognise the existence of a duty of care. Examples include one road-user to another employer to employee manufacturer to consumer doctor to patient solicitor to client teacher to student The common law position regarding negligence recognised strict categories of negligence. In 1932, the duty of a care applied despite no prior relationship or interaction and was not constrained by privity of contract. Here, a duty of care was found to be owed by a manufacturer to an end consumer, for negligence in the production of his goods. Mrs Donoghue's claim for damages for gastroenteritis and nervous shock were allowed, where a ginger beer manufacturer had negligently allowed a snail into a bottle, which she had consumed. Lord Atkin established liability on the basis that a neighbour principle existed between the two parties, to ensure reasonable care was taken in the production of the ginger beer, so as not to cause Mrs Donoghue any unreasonable harm: Lord Atkin's speech established a neighbour principle, or a general duty that individuals must take reasonable care in their actions or omissions, so as not to cause harm to others proximate to them. It did not matter that Mrs Donoghue was unidentified or unknown to the manufacturer; as the type of harm which occurred was foreseeable through the negligence of the ginger beer manufacturer. The Anns test Following the firm establishment of the neighbour principle in negligence, it became clear in subsequent years that it did not represent an easily applicable approach to new forms of duty, or to unprecedented situations of negligence. As such, new categories of negligence evolved, as in Hedley Byrne & Co Ltd v Heller & Partners Ltd, to cover different types of negligent acts, rather than a coherent doctrine or ratio being taken from Donoghue v Stevenson. Some thirty years after Donoghue was decided, in Home Office v Dorset Yacht Co Ltd, Lord Reid stated judicially that: "the time has come when we can and should say that it ought to apply unless there is some justification or valid explanation for its exclusion." It was not until the case of Anns v Merton London Borough Council however, that the neighbour principle was adopted in a formal test for negligence. The case involved the negligent construction of a block of maisonettes, commissioned by the Merton London Borough Council. The flats, finished in 1972, had poorly constructed