At common law there was no liability for injury caused by a death to any person other than the deceased1, except where a cause of action, such as a breach of contract, exists independently of the wrong causing the death. In those exceptional cases loss arising from the death may be included as an element of the damages2. For claims by dependants of the deceased, the common law rule has been substantially altered by statute, principally by the legislation incorporated in the Fatal Accidents Act 19763. There used to be a separate principle that claims in tort for personal
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