Gulliksen v Pembrokeshire council
Mount Estate in Milford Haven was built as a council housing estate in the early 1970s. Paths on the estate were inspected once a year by the council's highways department. An inspection took place in July 1998.

In May 1999, Mr Gulliksen was walking along a path on the estate when he caught his foot on the 3 cm-high lip of a manhole cover and fell, injuring his elbow. The council denied liability on the basis that the path was not a public highway but was provided for the use of tenants on the estate.

But the Appeal Court decided the path was a public highway because its purpose was to allow members of the public to get to houses on the estate. This meant the local highway authority was under a duty to maintain the path.

As the council, which was also the highway authority, could not show that it had taken all reasonable care to keep the path safe, it had to pay £3000 compensation.