“The categories of negligence are never closed”. [Lord Macmillan in Donoghue v. Stevenson- (1932)] The tort of negligence is a relatively recent phenomenon, which has become the most dynamic and evolving area of ​​liability in modern law. Lord Macmillan's assertion that "the categories of negligence are never closed" suggests that the courts possess the power to widen the scope of liability by introducing new situations of duty following the emergence of new facts . As it is difficult to define negligence in simple terms, it can be said that the 'neighbour' principle of duty of care remains, in its wider social context, one of the most important elements of negligence. Courts have historically been reluctant to grant relief to claims where there was no contract between the plaintiff and defendant with respect to policy consideration. The main reason given to justify this situation was the so-called “windows” argument. Courts should not grant relief in a particular case, as this would open the door to numerous claims in similar situations. The same was accepted as an obiter remark of Lord Buckmaster in his dissenting speech in Donoghue v. Stevenson. Decided by a 3-2 majority of the House of Lords, Donoghue v. Stevenson (1932) is considered the classic case in this regard, in part because he laid down the founding principle of modern negligence law. However, this can be better understood by looking at the previous cases that governed Donoghue v. Stevenson, where in similar factual circumstances negligence was not recognized. In Bates v. Batey & Co. Ltd., the defendants, manufacturers of ginger beer, were not held liable to a consumer (who had purchased one of their bottles from a retailer) for loss caused by the failure to the bottle, as it could have been avoided with reasonable care. Winterbottom v. Wright, A hired B to provide a mail coach to transport mail bags along a certain line of road.