Shaw v. . Barnard

A single action in tort for negligence may be maintained against two or more defendants only when the plaintiff relies on the doctrine of respondeat superior or the defendants are joint tort-feasors.

“An action cannot be maintained against two or more defendants for distinct torts which were committed by the different defendants independently of and not in connection with each other, although the consequences of the tort, which was committed by one defendant, united with the consequences of the tort which was committed by the other. In such case the one defendant cannot be made liable for the…