Samuel Fleming

“ Suddenly, the explosion occurred.
The Court finds:—
That the cause of the said explosion was the culpable negligence of J. W. Knowles. That, having regard to the terms of the said contract and to the circumstances aforesaid, it became and was the duty of Mr. H. Andrews and Mr. R. V. Dawkins to see that the said ammunition was broken down under proper precautions and that their negligence in that behalf was a contributing cause of the said explosion. I am, Sir,
Your obedient Servant,
S. Fleming
Lieut.-Colonel. ”

“ In pursuance of this contract the said ammunition, as stated in the Interim Report hereon, was ordered to be delivered to Knowles at the factory in Groveland Road aforesaid.
This factory, of which the workshop in question forms part, consists of several one-storey buildings surrounding an open yard. The roof of the said workshop consists of corrugated iron sheets, its floor is made of concrete and in the centre is a stove. ”

“ John W. Knowles,
"Manager"
"Groveland Road,
"Tipton,
"January 16th, 1922.
"Messrs. H. Andrews and R. Dawkins,
"Hay Mills,
"Birmingham.
"Dear Sirs,
"I hereby agree to divide all profits arising from the purchase of 160 tons of revolver ammunition as-to one-half between your good selves, the other half to be retained by me, and I agree that Mr. Martin, Accountant, of Dudley, shall have a fee of £5 5s. to audit the account in connection thereon, and, further, that his figures shall be binding.
"Yours faithfully,
" (Signed) John W. Knowles,
"Manager"
"January 18th, 1922. ”