Manufacturers have a legal duty of care to the ultimate consumers of their products if it is not possible for defects to be identified before the goods are received.[1]: 9 [4]: 643 Donoghue v Stevenson [1932] AC 562 was a landmark court decision in Scots delict law and English tort law by the House of Lords. It laid the foundation of the modern law of negligence in common law jurisdictions worldwi