[2003] EWCA Civ 1832, 19 December 2003. Appeal by appellant firm of architects PKS against HC decision ([2003] EWHC 142 (TCC), X121971) concerning PKS's liability for a fire which destroyed most of a food factory belonging to claimant (S). PKS argued that the judge was wrong to hold that they were negligent or in breach of contract or duty for failing to exercise reasonable care and skill in order to prevent the spread of fire. Alternatively, PKS argued that if in principle, they were liable, the judge was wrong to ignore S's admitted fault for starting the fire and for S's part in the spread of the fire which should have been reflected in an apportionment of damage under the Law Reform (Contributory Negligence) Act 1945 s1. "Held": appeal allowed in part. PKS's liability for fire upheld but S was held to be guilty of contributory negligence. Therefore, the damages recoverable by S from P were reduced by two-thirds. View decision at www.bailii.org.