Film Atlantic - Actress injured in recreation of Titanic scenes

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Court of Appeal

Actress's claim under Workmen's Compensation Act

Armour v. British International Pictures Ltd.

(Before the Master of the Rolls, Lord Justice Slesser and Lord Justice Romer)

Thecourt dismissed this appeal, from a decision of His Honour JudgeTurner, sitting at Westminster County Court, which raised the questionwhether Mrs Marie Armour, known professionally as Miss Marie Mischel,who was injured while acting as a "crowd artist" in the production ofthe film Atlantic on board a liner in Tilbury Dock, was aworkman within the meaning of the Workmen's Compensation Acts, and soentitled to claim compensation. The County Court judge decided that shewas not.

Mr Heathcote, who appeared for Mrs Armour, said that his client hadbeen knocked down, and her left knee seriously injured, to such anextent that it was doubtful whether she would again be able to takepart in film production. She had been acting with 400 other "crowdartists" on board the liner, staging a scene representing the sinkingof the Titanic and the rush for the boats.

It was difficult to say that Mrs Armour was not a workman; in otherwords, that she was an independent contractor, giving her services inher own way to achieve a certain result. Four hundred people doing eachone as he pleased would achieve nothing but confusion. The County Courtjudge had not given weight to the control exercised over these "crowdartists."

The Master of the Rolls, in giving judgement, said the question was asimple one, namely whether the appellant had entered into a contract ofservice; or whether she had merely agreed to render certain services.It was a question of fact, and the County Court judge, having heard allthe evidence, had decided as a fact that Mrs Armour was not the servantof the respondents. It was not for the court to interfere with hisdecision on a question of fact, and the appeal must be dismissed.

Lord Justice Slesser and Lord Justice Romer agreed.    

(The Times, Wednesday July 30, 1930, p. 4)

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Senan Molony


Encyclopedia Titanica (2005) Film Atlantic - Actress injured in recreation of Titanic scenes (The Times, Wednesday 30th July 1930, ref: #4947, published 17 December 2005, generated 31st July 2021 03:54:33 AM); URL :