In Capital and Counties v Hampshire County Council the alleged negligence consisted of a fire-fighter ordering that a sprinkler system, operating at the fire, should be turned off. In John Munroe it was alleged that the fire brigade left the scene before ensuring the fire was properly extinguished and in Church of Jesus Christ, the fire service failed to ensure that an adequate supply of water was available at the scene of the fire. It was held in all of these cases that the fire brigade’s attendance at the scene of a fire did not, in itself, give rise to the requisite degree of proximity and it, therefore, followed that the fire brigade was under no duty to attend to the fires in the first place. Here the court simply followed the reasoning in Alexandrou (see 3.4.2 above) i.e. no duty to respond to an emergency.