40  For a tort to exist, the defendant needs to have caused the harm to the plaintiff  Cause-in-fact  But for the defendant's actions, would the harm have occurred  Proximate cause  Immediate cause – defendant's action can't be too distant from the harm  Palsgraf v Long Island Railway (NY Ct Appeals, 1928):  Guard pushed a passenger to help him onto train, passenger dropped fireworks he was carrying, they went off, explosion knocked down scales at the other end of the platform, which fell on Mrs.
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