Thos Borthwick and Sons (Australasia) Ltd v Ryan - [1932] NZLR 225

Workers' Compensation — Accident — Whether Injury caused by Accident as a Result of a Severe Earthquake arose "out of" the Employment — Proximate and Efficient Cause — General Risk and "Locality Risk" — Facts insufficient to prove Liability to Special Risk — Right to bring Action in Arbitration Court not barred — Declaratory Judgments Act, 1908 — Workers' Compensation Act, 1922, s 3.