In Forsikringsaktieselskapet Vesta v Butcher [1986] 2 All ER 488, Hobhouse J identified the following categories of obligation:
1. Where the defendant's liability arises from a breach of a strict contractual duty.
2. Where the defendant's liability arises from a contractual obligation which is expressed in terms of taking care (or its equivalent), but does not correspond to a common law duty to take care which would exist in the given case independent of contract.
3. Where the defendant's liability in contract is the same as his liability in the tort of negligence which arises independently of the contract.