21.   There was also some damage by fouling to the wharf.

22.   Damage by explosion was probably not a foreseeable kind of damage.

23.   Damage by eruption was not foreseeable in the circumstances but damage by splashing was.

24.   We have seen that in Wagon Mound they did not define the kind of damage necessary as property damage but distinguished between damage by fouling and fire damage.

25.   This principle is illustrated in relation to property damage by the following case.

26.   Where a statute imposes a duty on a person, breach of that duty may give rise to an action for damages by a person injured as a result.

27.   Not all breaches of statutory duty will give rise to an action for damages by a person injured as a result.

28.   Sediments providing essential food for fish are vulnerable to damage by heavy trawling gear.

29.   But an adverse ruling from a private body is much less daunting and much less publicised than a heavy award of damages by judge or jury.

30.   The practical significance of this change is mainly to reduce the damages by removing one possible plaintiff, rather than by removing the prospect of an action.