development in searching for a liability in tort where the parties are in a contractual relationship." The allowance of concurrent actions was immensely controversial, as it ran contrary to legal orthodoxy. Lord Goff said the following. See also Caparo Industries plc v Dickman La règle de non-cumul in French law Notes English contract case law English tort case law House of Lords cases English privity case law 1994 in case law 1994 in British law