In Spring v Guardian Assurance plc & Others [1994] 3 All ER 129 the defendants gave a very disparaging job reference about the plaintiff. The plaintiff was unable to gain other employment in the life assurance industry as a result of the reference and, therefore, sued the defendant for negligence. Although there was no doubt that a referee owed a duty of care to the person requesting a reference (Hedley Byrne), it was questionable whether a duty of care was also owed to the subject of the reference. The Court of Appeal held that the plaintiff’s only remedy would be in defamation, not negligence. However, the House of Lords (Lord Keith dissenting) held that there could be a duty of care. Lord Goff based his reasoning on the concept of assumption of responsibility. He felt that by giving a reference, the company assumed a responsibility to the plaintiff to give a careful reference. It is very difficult to get a job without a reference and a defamation action would not always provide a satisfactory remedy.