Although the neighbour principle was a critical part of Lord Atkin's reasoning, and was therefore part of the "ratio" of his judgment, neither of the other judges in the majority expressly endorsed the principle. Robert Heuston therefore suggests that case only supports the claims there can be duties in tort even if there is no contract; that manufacturers owe a duty of care to the ultimate consumers of their goods; and possibly that negligence is a separate tort. "No amount of posthumous citation can of itself transfer with retrospective effect a proposition from the status of "obiter dictum" comments to that of "ratio decidendi"."