67. Occurrences that cannot happen without carelessness.

The harm must be of such a kind that it does not ordinarily happen if proper care is being taken. The doctrine of res ipsa loquitur1 has been applied to things falling from buildings2, and to accidents resulting from defective machines, apparatus or vehicles3. It has also been applied where motor cars mount the pavement4 or where aircraft crash on taking off5. On the other hand, it was held inapplicable where a fire, having been left by a lodger in his grate, spread from his room and damaged neighbouring rooms