Lord Thankerton ruled that Donoghue had no contract with Stevenson, nor that her case was covered by one of the scenarios in which a duty of care had previously been found. However, he held that where goods could not be examined or interfered with, the manufacturer had "of his own accord, brought himself into direct relationship with the consumer, with the result that the consumer entitled to rely upon the exercise of diligence by the manufacturer to secure that the article shall not be harmful to the consumer", an exception to the general nonexistence of a duty of care that applied to Donoghue.