As early as 1936, only four years after the decision in Donoghue, the concept of negligence was further expanded in the Australian case of Grant v Australian Knitting Mills  AC 85. In this case the manufacturers failed to remove a chemical irritant from their woollen underwear. Grant, upon wearing the undies, contracted dermatitis. He then sued Australian Knitting Mills for damages.
The Court used Donoghue as a persuasive precedent and expanded the legal principles established in Donoghue to include all manufacturers. It also clearly set out the elements necessary to prove in order for an action in negligence to be successful. The court stated that it must be shown:
- that a duty of care was owed by the defendant to the pursuer (claimant)
- there was a breach of that duty owed through the pursuer not acting to the standard expected
- that damage was suffered as a result of that breach.