In the UK, courts have adopted aclose connection testfor respondent superior liability. In a March 2016 case, this resulted in a supermarket being held liable when one of its employees followed a customer out to his car and "subjected him to a serious attack, involving punches and kicks." The court observed that this was the result of an "unbroken sequence of events," and that there was a sufficient connection between the employment and the employee's behavior to justify imposing liability. This was in spite of the court's acceptance of the fact that the attack was motivated by personal racism rather than a desire to benefit his employer's business. As far as I know no US court has adopted this approach.

In other systems, including Sharia law, each individual is responsible for their own tortious (wrongful) acts. The liability is not separated from the fault. See page 434.

Which system do you think is best, the US scope of the employment rule, the UK close connection rule or the rule placing liability only on the person who engaged in the wrongful act?