In Case 1, a Man Was Walking His Rottweiler Dog

In case 1, a man was walking his Rottweiler dog in the park. The dog bit a woman in an unprovoked attack. The dog had bitten someone before and the owner was aware of this. The Court of Appeal decided that that the man was liable. According to an academic commentator, the ratio of the case is: 'The owner of a dog that had bitten someone before, where the owner was aware of this, is liable in negligence for any injury caused in a public place.'
In case 3, an Alsatian dog bit a postman while in its owner's front garden. The dog had never bitten anyone before. The Court of Appeal decides that the owner is liable on the grounds that 'the principle of liability established in case 2 is applicable, even where the dog is on private property and not in a public place, whether or not the dog has bitten someone before and the owner is aware of this.'
The ratio of case 3 is narrower than that of case 1.