Question:medium

Pigeon Hole theory was proposed by

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For the Law of Torts, remember the two foundational theories: Salmond's theory is "Law of Torts" (plural, meaning a collection of specific torts like pigeon-holes). Winfield's theory is "Law of Tort" (singular, meaning a general principle of liability for all unjustifiable harm).
Updated On: Jul 13, 2026
  • Winfield
  • Salmond
  • Black Stone
  • Lord Knight
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The Correct Option is B

Approach Solution - 1

This is best approached by remembering the two competing schools of thought on the scope of tort law and matching the description to the right one.

  1. Fix the two camps: Torts scholarship has traditionally been divided between those who say liability is confined to specific, named wrongs (a closed list) and those who say liability flows from one general principle covering any unjustifiable harm.
  2. Match the description: The question describes a fixed set of "pigeon-holes" that a claim must fit into, which is the closed-list view, associated specifically with Salmond, not with Winfield, whose general-principle theory is the opposing position.
  3. Rule out the distractors: Blackstone and "Lord Knight" are not associated with this particular classification debate in tort law at all, so they can be set aside without further analysis.

The correct answer is Salmond.

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Approach Solution -2

A helpful memory anchor is the metaphor itself: pigeon-holes are separate, individually labelled compartments, and that image should point directly to the jurist who used it.

  1. Winfield: His view is often remembered through the phrase "law of tort" in the singular, describing one broad wrong (unjustifiable harm) rather than a set of separate compartments, so the pigeon-hole imagery does not belong to him.
  2. Salmond: Salmond's position is remembered through the phrase "law of torts" in the plural, a list of distinct, separately defined wrongs. This is precisely the image of separate compartments that "pigeon-hole" evokes, and it is Salmond's name that textbooks consistently attach to this theory.
  3. Black Stone: Blackstone predates this specific torts classification debate and worked on English law in a much broader historical sense, so the pigeon-hole label is never attributed to him in tort law texts.
  4. Lord Knight: No established torts scholarship attributes any classification theory to a jurist by this name, making this option a non-existent authority for the theory described.

The compartmentalised imagery in the question points squarely to Salmond's closed-list theory.

Hence, the correct answer is Salmond.

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