“…e question. I do not think it does, however. Lord Steyn made the remark in the course of the following discussion of Hobhouse LJ’s judgment in Downs v Chappell [1997] 1 WLR 426:…”
“…ss or has a greater causative effect than a wrongdoer whose conduct is less causatively potent. This was explained by Lord Justice Hobhouse in Downs v Chappell [1997] 1 WLR 426, 445, where one defendant had been fraudulent and the other negligent, but on the facts it was the latter’s conduct which had the greater causative effect:…”
“… to rely on, but the Recital itself refers to the ‘relative responsibility of a given infringer’ and criteria such as ‘role in the cartel’. In Downs v Chappell [1997] 1 WLR 426 (CA) where responsibility fell to be apportioned between defendants, Hobhouse LJ said at 445H that ‘it is just and equitable to take into account both the seri…”