A claimant must prove that a duty of care is owed using the three-part test set out in the case of Caparo v Dickman. Briefly explain the first part of the test.

The first part of the test in Caparo v Dickman states that a defendant is liable if loss to someone in the claimant’s position was a reasonably foreseeable consequence of the defendant's conduct.
The test of reasonable foreseeability in the first part of the test is significant as it acts as a limit to liability; a defendant is not liable for all actions that may cause harm, but only for those actions where it was reasonably foreseeable harm would be caused. Notably, following Jolley v Sutton, it was confirmed that the 'loss' that must be reasonably foreseeable is the same 'kind of injury' that was in fact suffered by the claimant. Thus, in that case, the Council was liable for injury caused by a derelict boat falling on a child as it was reasonably foreseeable that the boat may cause injury in some capacity even if the boat falling was not specifically foreseeable. Reasonable foreseeability has also been used to impose liability in 'omission cases', where typically English law does not find fault. In Kent v Griffiths, it was held that the local ambulance service was liable for failing to arrive in time to help a patient as it was reasonably foreseeably that any delay would result in injury. Thus, the first part of the test has also been used to expand liability in areas where the courts have also thought it 'fair, just and reasonable'.