Abstract
An intriguing question, which until recently had not been directly explored by the courts, is the extent to which English law recognises body parts and products of the human body as property capable of ownership. Although the common law currently recognises no general property in a dead body (and only limited possessory rights in respect of it), this apparent “no-property rule” provides no justification, it is submitted, for denying proprietary status to parts or products of a living human body. The recent decision of the Court of Appeal in Yearworth v. North Bristol NHS Trust ([2009] EWCA Civ 37) lends strong support to the view that genetic material (as the product of a living human body) is capable of ownership, at least in the context of a claim in the tort of negligence and bailment. This article examines the various issues by reference to both English and Commonwealth authority.
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Notes
Exelby v. Handyside (1749) 2 East P.C. 652; R. v. Lynn (1788) 2 T.R. 733; 100 E.R. 394; R. v. Sharpe (1857) Dears. & Bell 160; 169 E.R. 959, per Erle J.; Foster v. Dodd (1867) L.R. 3 Q.B. 67, per Byles J.; R. v. Price (1884) 12 Q.B.D. 247, per Stephen J.; Williams v. Williams (1882) 20 Ch. D. 659, at p. 664, where Kay J. said: “the law of this country recognises no property in a corpse”; Re Dixon [1892] p. 386; and Lee v. Harvey [1898] p. 63.
By contrast, materials as abstract as gas and electricity can be possessed and stolen: R. v. White (1853) Dears C.C. 203; 169 E.R. 696. Vibration has been treated as an “object” in trespass and nuisance law: Hoare and Co v. McAlpine [1923] 1 Ch. 167, at p. 175, per Astbury J. Computer software has been held to be property within the meaning of the Criminal Damage Act 1971: Cox v. Riley (1986) 83 Cr. App. Rep. 54. It has also been held to constitute “goods” for the purposes of the Sale of Goods Act 1979: Saphena Computing Ltd v. Allied Collecting Agencies Ltd; St Albans City and District Council v. International Computers Ltd; Toby Construction Products Property Ltd v. Computa Bar (Sales) Property Ltd [1983] 2 N.S.W.R. 48.
See, Haynes’ Case (1614) 12 Co. Rep. 113; 77 E.R, 138, where there is a judicial reference to a cadaver as being “but a lump of earth”. By an ordinance of William the Conqueror, the temporal and spiritual jurisdictions were severed and control of churchyards and burials was absorbed by the ecclesiastical authorities. By the middle of the nineteenth century, the ecclesiastical jurisdiction had declined significantly in importance and more bodies were being buried in unconsecrated ground.
Jackson (1950, p. 126): “[The Church] held that a corpse was appropriated by it, by divine service and consecrated burial. The spirit departed to the realms of the supernatural; the body was held by the divine agent to await resurrection”.
In 1804, Lord Ellenborough declared such arrest illegal as being contrary to the public interest: Redfield’s Surr. Rep. Vol. 4, p. 527. See also: R. v. Fox (1841) 2 Q.B. 246 and R. v. Scott (1842) 2 Q.B. 248n.
This is expressly acknowledged in the Canadian case of Miner v. Canadian Pacific Railway Co. (1910) 15 W.W.R. 161, at pp. 166–168.
Price (1951, p. 404). See also, Griffith C.J. in Doodeward v. Spence (1908) 6 C.L.R. 406, (High Court of Australia), at p. 412: “I do not myself accept the dogma of the verbal inerrancy of ancient text writers. Indeed, equally respectable authority, and of equal antiquity, may be cited for establishing as a matter of law the reality of witchcraft”.
See, Brotherton v. Cleveland (1990) 923 F. 2d 477, (6th. Cir. C.A.), at p. 480. See further, Olender (1960, pp. 523–531).
The usual basis of damages is mental distress and anguish caused to the relatives. See, for example, Gonzales v. Metro Dade City Health Trust (1995) 651 So. 2d 673, (Supreme Court of Florida), where it was held that an action for mental anguish based on negligent handling of a dead body could be brought by relatives of the deceased if physical injury could be proved or the defendant’s conduct was wilful or wanton; Mackey v. U.S. (1993) 8 F. 3d 826, (United States Court of Appeals), noted in [1995] Med L.Rev. 222. In England, negligently inflicted mental distress is irrecoverable unless part of a “pain and suffering” claim arising out of physical injury: Alcock v. Chief Constable of South Yorkshire Police [1991] 4 All E.R. 907, (HL). If, on the other hand, the defendant interfered with the body with the intention of causing harm to the plaintiff, then the rule in Wilkinson v. Downton [1897] 2 Q.B. 57 would apply and an action would lie for any recognised psychiatric injury: see further, (1996) 4 Med. L. Rev. 216, where it is argued that a negligence action would only succeed if the plaintiff satisfied the Alcock rules for recovery of damages for psychiatric injury as a “secondary victim”. On this basis, the deceased’s relatives would need to “witness” the mishandling of the body in order to succeed: cf. Owens v. Liverpool Corporation [1938] 4 All E.R. 727, (CA), where a claim for psychiatric injury by relatives of a deceased who witnessed an accident involving the hearse carrying the body was upheld.
See, 42 U.S.C., s.1983 and Whaley v. County of Tuscola (1995) 58 F. 3d 1111, (6th Cir. C.A.). See further, T. O’Carroll (1996), for a critique of the Whaley decision.
The Theft Act 1968 does not appear to have altered the position since the statute must still be construed in the light of common law rules as to property. The Criminal Law Revision Committee Report, “Theft and Related Offences”, (1966, Cmnd. 2977) makes no mention of human corpses.
See, e.g. R. v. Harmsworth [1975] Crim L.R. 525 and R. v. Farrant (1975) 61 Cr. App. Rep. 200.
Williams v. Williams (1882) 20 Ch. D. 659, at pp. 664–665, per Kay J., who said (at p. 665): “If there be no property in a dead body it is impossible that by will or any other instrument the body can be disposed of”. For the same reason, an heir has no property right in the body of his ancestor. Contrast the American position where the deceased has the right to determine the manner of disposal by will (or even contract) of his or her body organs. See further, Barish (1956), who argues that the reasonable wishes of the deceased concerning the final disposition of his body should be paramount to all other interests.
By contrast, see the American case of Re Eichner’s Estate, 18 N.Y. (2d) 573, where it was held that: “the wishes of the deceased in respect of the disposal of his remains as expressed in his will, if reasonable, practical and possible, are paramount to all other considerations, even the opposition of surviving relatives”.
See now, the Human Tissue Act 2004.
The Canadian case of Edmond v. Armstrong Funeral Home Ltd [1931] 1 D.L.R. 676 lends some support for a tort of interference with the right to possession of the body. But see, McColl Kennedy (1976, p. 50), who favours liability in negligence where nervous shock is caused, or a tort of breach of statutory duty.
Haynes’ Case (1613) 12 Co. Rep. 113.
See, e.g. Elwes v. Brigg Gas Company, (prehistoric boat submerged in the land); (1886) 33 Ch. D. 562; R. v. Jacobson (1880) 14 Cox C.C. 522, (buried bones turned into dust). See also, Doodeward v. Spence (1908) 6 C.L.R. 406, at p. 412, (High Court of Australia), where Griffiths C.J. opined that: “after a burial a corpse forms part of the land in which it is buried, and the right to possession goes with the land”.
It has been argued that ashes which are retained unburied should be the subject of property like other bodily products: see, Matthews (1983, pp. 206–207). But see, Bourne v. Norwich Crematorium Ltd [1967] 2 All E.R. 567, where the court rejected the submission that cremation constituted the “subjection of goods or materials to a process” within the Income Tax Act 1952.
At one time, a wife was considered to be the property of her husband: see, Hopkins v. Blanco 320 A. 2d. 139 (1974). See also, Gregson v. Gilbert (1783) 3 Dougl. 232; 99 E.R. 629, (slaves pushed overboard from a boat running short of water held to constitute a throwing overboard of goods). At common law, a debtor could be personally attached to force payment of the debt: see, further, Notes (1976, p. 543).
The Abortion Act 1967, as amended.
Prohibition of Female Circumcision Act 1985.
See, for example, R. v. Brown [1992] 2 All E.R. 552, (CA), affmd. [1993] 2 All E.R. 75, (HL), where consent to sado-masochistic acts was held not to be operative consent.
(1983) 36 Current Legal Problems 193, at p. 223.
See, Santos v. Illidge (1860) 8 C.B. (N.S.) 861; 141 E.R. 1404.
For example, an employer has no property rights over his employee and cannot ordinarily obtain specific performance of his employment contract compelling him to work.
See, Skegg (1997, p. 228).
[1996] 4 All E.R. 474, (C.A.). See also, Williams v. Williams (1882) 20 Ch. 659.
Clark v. London General Omnibus Co Ltd [1906] 2 K.B. 648, at p. 659, per Lord Alverstone C.J., but see also Farwell L.J., at p. 683, who expressed doubts. See also, R. v. Vann (1851) 2 Den. 325, (where it was held that a father was under a duty to dispose of the body of his deceased child if he has the means to do so) and R. v. Gwynedd C.C., ex parte B (1991) 7 B.M.L.R. 120, (C.A.).
Ambrose v. Kerrison (1851) 10 C.B. 776; Bradshaw v. Beard (1862) 12 C.B. (N.S.) 344. See further: S.G. Hume (1956–58, p. 109).
R. v. Bristol Coroner, ex parte Kerr [1974] Q.B. 652.
See, R. v. Stewart (1840) 12 Ad. & El. 773. It has been held that the master of a workhouse was in lawful possession of a body lying in the workhouse: R. v. Feist (1858) Dears. & B. 590.
This is the view put forward by Lanham (1971, p. 20), who argues that, until the executors or relatives know about the death, the hospital must be regarded as lawfully in possession of the body. Even mere knowledge of the death may not be sufficient to vest possession (i.e. there must be an intention to possess communicated to the hospital). See also, de Stoop (1974, p. 22), who submits that “the person who has actual physical custody of the body has lawful possession (and the duty of disposal) of it until someone with a higher right (for example, an executor) claims the body”. It has also been suggested that close relatives should have a right to possess the body as the person(s) next entitled to be appointed the administrator of the deceased’s estate under the Non-Contentious Probate Rules, rule 22, namely, the surviving spouse, children, parents, siblings, and so on: see, [1996] 4 Med. L. Rev. 216, at p. 218.
An order of mandamus will lie to compel delivery of a corpse to the person charged with the duty of burying it: R. v. Fox (1841) 2 Q.B. 246.
Waldman v. Melville (City) [1990] 2 W.W.R. 54, (Sask. Q.B.).
Thorpe and Butler-Sloss L.JJ. agreeing.
This is, of course, in sharp contrast to the American position, as mentioned earlier.
Clerk and Lindsell (1995).
(17th ed., 1995), at p. 653.
See further, Skegg (1997, p. 224), who argues that this would be “a very significant qualification of the no property rule”. As he rightly points out, there would be little sense in drawing a legal distinction between bodies awaiting burial or cremation which have been embalmed and those which have not.
See, the interesting discussion in Magnusson (1993, pp. 248–249), in relation to the trade of Aboriginal body parts.
(1884) 12 Q.B.D. 247.
(1908) 6 C.L.R. 406 (High Court of Australia). See also, the early case of Herring v. Walround (1682) 2 Ch. Cas. 110; 22 E.R. 870, (embalmed bodies of Siamese baby twins) and Exelby v. Handyside (1749) 2 East P.C. 652, (two female dead infants joined together at the stomach).
Griffith C.J. and Barton J., Higgins J. dissenting.
The leading judgment was given by Griffith C.J., Barton J. (the second member of the High Court) limited the right of action in detinue to a still-born foetus only emphasising that, as a general rule, an unburied corpse was not capable in law of becoming the subject of property. In his view, a still-born foetus did not fall within the no-property rule because it was not the corpse of a once-living person. There was, therefore, no objection to recognising it as property under the common law. The third member of the Court, Higgins J., dissented, being of the firm view that no one could have property in another human being (whether alive or dead). In his view, “the only lawful possessor of a dead body is the earth”: ibid, at p. 423.
The assumption in Peter Gibson L.J.’s judgment is that the plaintiffs would have owned the deceased’s brain if the requisite work had been done on the brain. It has been suggested that this is wrong unless the brain was theirs before the work was done. Where the specimen belongs to no one at the time of work, “the doer of the work ought to acquire the proprietary interest in it”: see, [1997] Med. L. Rev. 110, at pp. 113–114.
[1996] 4 All E.R. 474, at p. 479.
[1996] 4 All E.R. 474, at p. 478.
(1882) 20 Ch. D. 659.
[1998] 3 All E.R. 741, (CA).
See, R. v. Turner (No. 2) [1971] 2 All E.R. 441, (CA). See further, Commentary (1998, pp. 251–253).
[1998] 3 All E.R. 741, at p. 749.
See the judgment of Griffith C.J., who refers to the fact that the body “had acquired an actual pecuniary value”: ibid, at p. 415. Barton J. also alludes to the body having a “considerable monetary value”: ibid, at p. 416.
The fact that the object of theft has little or no intrinsic value is no defence, but may be relevant to mitigation of sentence. See further [1976] Crim. L.R. 329, 330.
See, Commentary (1998, p. 250).
See generally, Matthews (1981).
Interestingly, s.32 of the Human Tissue Act 2004 prohibits commercial dealings in human material intended for transplantation but, by s.32(9)(c), it does not apply to “material which is the subject of property because of an application of human skill”.
Nor, indeed, would it apply to anatomical specimens which had not been the subject of any process of skill (e.g. bodily parts preserved in formalin or paraffin).
See, Skegg (1974, p. 53).
[1961] J.P.L.G.R. 12.
[1974] R.T.R. 478 (appeal against sentence).
[1976] R.T.R. 550.
(1976) 354 A. 2d 483, (Md. Ct. of Spec. Apps.), at pp. 498–499.
249 Cal. Rptr. 494 (1988) (Court of Appeal of California).
(1974) 504 S.W. 2d. 713 (Ky. C. A.).
See the observation in Haynes’ Case (1614) 12 Co. Rep. 113: “A man cannot relinquish the property he hath to his goods unless they be vested in another”. In other words, the law abhors a vacuum.
But using body parts to make artefacts may be held to constitute the common law offence of outraging public decency: R. v. Gibson [1990] 2 Q.B. 619 (CA), where a freeze-dried human foetus was used to make earrings displayed in an art gallery open to the public.
Moore v. Regents of the University of California 793 P. 2d (1990) 479 (Supreme Court of California).
20 Cal. Rptr. 2d 275 1993 (California Court of Appeals).
793 P. 2d (1990) 479 (Supreme Court of California).
See, for example, Davis v. Davis (1992) 842 S.W.2d 605 (Supreme Court of Tennessee), holding that the parents of frozen pre-embryos had a decision making authority, an interest in the nature of ownership, to order their disposition; and (1989) York v. Jones 717 F. Supp. 421 (District Court for the Eastern District of Virginia), holding that the donors of gametes have the right to decide their disposition within medical and ethical guidelines.
See, Senate Select Committee on the Human Embryo Experimentation Bill 1985, Human Embryo Experimentation in Australia, Report (1986), para. 2.21.
See, in particular, the Abortion Act 1967.
Paton v. Trustees of B.P.A.S. [1979] Q.B. 276, at p. 279, per Baker P.; C v. S [1988] 1 Q.B. 135 (C.A.); Re F (in utero) [1988] Fam. 122 (C.A.); and R. v. Tait [1990] 1 Q.B. 290 (C.A.). Cf: the Congenital Disabilities (Civil Liability) Act 1976, which makes provision for civil liability in the case of a child being born disabled in consequence of some person’s default.
Noted in G. Dworkin and I. Kennedy (1993, p. 301, n. 36).
(1992) 842 S.W. 2d 605, (Supreme Court of Tennessee). See further, Commentary, “Frozen Embryos: Legal Status, Disposition and Control” (1993) Med. L. Rev. 273.
(1989) 717 F. Supp. 421 (District Court for the Eastern District of Virginia).
It has been argued that vesting decision-making control in the couple gave them, in effect, a “form of quasi-ownership or pseudo-propriety interest” in the frozen embryo: “What was this power if not that of an owner over his property?”: see, Commentary, “Frozen Embryos: Legal Status, Disposition and Control” (1993) Med. L. Rev. 273, at p. 277.
See, Schedule 3.
Yearworth v. North Bristol NHS Trust [2009] EWCA Civ 37.
Ibid, at para.45.
Ibid, at para. 45.
The Court of Appeal cited a land owner’s ability to build on his land or to evict his tenant at the end of the tenancy or a pharmacist’s ability to sell his medicines.
793 P. 2d (1990) 479, (Supreme Court of California). See, generally, Dickens (1992). There has been a huge volume of American legal literature on the Moore decision.
The majority of the Court felt that extending conversion liability in this way would have a devastating effect on biotechnological research.
See (1983) 36 Current Legal Problems 193, at p. 259.
The donor’s share in the profits may be small, bearing in mind the amount of work and skill employed in the development of the biotechnological product: see further, Matthews, “Freedom, Unrequested Improvements, and Lord Denning”, [1981] C.L.J. 340.
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Pawlowski, M. Property in Body Parts and Products of the Human Body. Liverpool Law Rev 30, 35–55 (2009). https://doi.org/10.1007/s10991-009-9052-2
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DOI: https://doi.org/10.1007/s10991-009-9052-2