An employer giving a reference is under a duty to the subject of the reference to take reasonable care in compiling it, or in obtaining the information on which it is based, holds the House of Lords in Spring v Guardian Assurance plc and others.
In Lawton v BOC Transhield Ltd the High Court rules that an employer owes an ex-employee a duty of care when giving a reference to a prospective employer. But the court holds that the defendant company was not negligent in the particular circumstances as there was ample evidence to support the opinions expressed in the reference.