Wagon Mound (No 1) [1961] AC 388. In this case the defendants negligently caused oil to spill into Sydney Harbour. The oil spread a distance of 600 feet into the vicinity of a ship called The Corrimal which was berthed at the plaintiff’s wharf. Two days later welding operations on The Corrimal caused a spark to come into contact with harbour rubbish floating on the oil. The resulting fire caused extensive damage to the plaintiff’s premises. While this was a direct result of the defendant’s negligence, the court held that it was not foreseeable damage. Damage by pollution was foreseeable, but damage by fire was not. The defendants were held not to be liable.