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The decision in Mullin v Richards14 confirmed in English
law the test of the standard of care required of child defendants, following the Australian case of
McHale v Watson.15 The defendant in Mullin was
a child aged 15 and Hutchison LJ said
that in determining whether she had been negligent the question
... is not whether the actions of the defendant were such as an ordinarily prudent and
reasonable adult in the defendant's situation would have realised gave rise to a risk of injury, it is
whether an ordinarily prudent and reasonable 15-year-old schoolgirl in the defendant's situation would
have realised as much.16
14 Mullin v Richards  1 WLR 1304 (CA).
15 McHale v Watson (1966) 115 CLR 199.
16 Mullin(n 14)1308.
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