In Scott v London and St Katherine Docks & Co (1865) 3 H & C 596, the claimant was injured when a number of large sacks of sugar fell onto her. She could not explain how this had occurred. However, since the sacks were in the defendant’s control, the court was prepared to infer that the accident had been due to the defendant’s lack of care, i.e. the sacks could not have fallen by themselves.