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Duty of Care - A review of the Dennis v Norwegian Refugee Council Ruling and its Implications

The purpose of this paper is to reflect on the court case and what lessons can be drawn from the Court’s ruling for the international aid sector. In order to achieve this, the paper reviews the Court’s legal reasoning and highlights the interrelation between the ruling, the concept of legal duty of care and security risk management. The paper concludes by providing an overview of some of the wider implications this case has for the international aid sector.


On 29 June 2012, Steven Dennis, an employee of the Norwegian Refugee Council (NRC), was injured and kidnapped, along with three other colleagues, following an attack during a VIP visit to the IFO II refugee camp in Dadaab, Kenya. Four days later the hostages were set free during an armed rescue operation carried out by Kenyan authorities and local militia. Three years later, Dennis submitted a claim at the Oslo District Court against his former employer, the NRC, for compensation for economic and non-economic loss following the kidnapping. The Court concluded that the NRC acted with gross negligence in relation to this incident and found the NRC to be liable for compensation towards Dennis.

Dennis pursued three legal claims against the NRC. With a focus on determining negligence in relation to the incident, the Court considered and reached conclusions on the following: the foreseeability of risk, mitigating measures to reduce and avert risk, gross negligence, causation and loss.