High Court dismisses negligence claim in snowmobile accident case

The High Court's recent decision in Andrew Cannestra v McLaren Automotive Events Limited [2025] EWHC 1844 (KB) provides significant guidance on the boundaries of duty of care in adventure sports contexts. Mr Justice Ritchie's judgement, delivered on 18 July 2025, examined a negligence claim arising from a snowmobile accident during a driving experience event in Lapland.

The claimant, a neurosurgeon from Jacksonville, Florida, had purchased two McLaren road cars and enrolled in the defendant's high-performance driving experience on snow-covered terrain. During the February 2020 event, he participated in additional snowmobiling activities. Whilst following a guide on a snowy track, he lost control and collided with a tree, sustaining injuries that formed the basis of his negligence and breach of contract claims.

The case centred on whether McLaren Automotive Events Limited's staff provided adequate safety instruction before the snowmobiling experience commenced. The judgement scrutinised the particulars of the safety briefing, noting that whilst it covered essential elements, it fell short of explicit discussions regarding the emergency stop button, throttle operation, and specific hazards related to left-hand turns—factors that featured prominently in the accident.

The court examined the Package Travel and Linked Travel Arrangements Regulations 2018, establishing the defendant's accountability for its staff's actions under these regulations. The standard of care was determined to align with local safety practices in Finland, where the incident occurred.

The evidence presented included substantial witness testimonies, digital and physical document bundles, mobile phone screenshots, and accident statistics. The claimant's case initially proceeded on the belief that he was at fault, but following legal consultation, formal proceedings were initiated.

Mr Justice Ritchie found that whilst the defendant breached its duty of care by failing to look back at a critical point whilst guiding the group, this had no direct causative impact on the accident. The claimant's decision to accelerate inadvertently whilst navigating turn two was identified as the primary cause of his injuries. The court concluded that he acted contrary to advised safety practices, inadvertently applying the throttle during the left turn.

This determination reinforced the defendant's position that adequate instruction had been provided, and the claimant's actions led to the collision. The judgement noted that the guides had adhered to industry standards and provided appropriate supervision and guidance throughout the experience.

The court rejected the claimant's negligence claims entirely, dismissing the case. The judgement emphasised the importance of clear communication and training in adventure sports, whilst serving as a cautionary reminder regarding high-risk activities.

The decision illustrates the court's commitment to evaluating factual contexts meticulously, balancing duty of care with individual responsibility within adventure sports liability. The case establishes that operators may fulfil their duty of care through adequate instruction and supervision, even where minor procedural breaches occur, provided these do not causatively contribute to the claimant's injuries.

This judgement reinforces the principle that participants in adventure sports bear significant responsibility for their own safety, particularly where they act contrary to safety instructions. The decision will likely influence future cases involving adventure sports operators, establishing clearer parameters for the scope of duty of care in such contexts.

The case also highlights the relevance of local safety standards in determining appropriate care levels, particularly in international adventure tourism contexts where different jurisdictions may apply varying safety protocols and expectations.