Jurisdiction(s):
United Kingdom

Spectator injuries at sporting events: occupiers’ liability, assumption of risk and participant negligence in UK case law

Published on: 30 September 2025

Published by a LexisNexis PI & Clinical Negligence expert

Legal News

Article summary

In May 2025, Golfweek stated that Spanish golfer Jon Rahm hit a supporter with a golf ball during the 2025 PGA Championship. That episode was said to be the third occasion on which this player had inadvertently struck a spectator with a shot. On the earlier instance, in 2022, the injured onlooker — a news presenter — was reported to have sustained injuries to the face. While there is extensive case law on the duty of care owed between participants in sport, what is the legal position when a spectator, or an employee carrying out duties at a match, is hurt by a golf ball, football, ice hockey puck, vehicle, horse or even a player who unintentionally leaves the field of play? Although it might feel reasonable that they should be able to recover damages from the organiser of the event, or even the player involved, is that analysis correct in law? The courts have revisited this question many times over many decades. Regrettably for would-be claimants, these actions are notoriously difficult to win. Most reported decisions favour the defending club or arena, although golfers appear to be the most vulnerable to claims succeeding...

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