"Res ipsa loquitur" does not shift any burden of proof or onus from one party to the other. The phrase is merely a handy phrase used by lawyers. The doctrine exists in both English law and Scots law. In English tort law, the effect of "res ipsa loquitur" is a strong inference in favour of the claimant that negligence has taken place. It does not however fully reverse the burden of proof ("Ng Chun Pui v. Li Chuen Tat", 1988). The requirement of control is important in English law. This requirement was not satisfied in "Easson v. LNE Ry" [1944] 2 KB 421, where a small child fell off a train several miles after it had left the station. It was considered that the door of the train was not sufficiently under control of the railway company after the train started moving and could have been opened by somebody for whom the company was not responsible. This case was distinguished from the earlier "Gee v. Metropolitan Ry" where the plaintiff fell from the train immediately after it left the station, when the door through which he fell could still be considered to be fully controlled by the railway company. The requirement that the exact cause of the accident must be unknown is illustrated by the case of "Barkway v. South Wales Transport". In this case a bus veered across the road and it was known that the accident was caused by a flat tyre. In this case, the plaintiff could not be assisted by "res ipsa loquitur" and had to go on to prove that the flat tyre was caused by the transport company's negligence. The doctrine exists in the Scots law of "delict". The leading case is that of "Scott v London & Catherine Dock Co". This case laid down 3 requirements for the doctrine to apply:  In "Scott", the court held that sacks of sugar do not fall out of warehouses and crush passers-by without somebody having been negligent along the way. Recent examples in Scotland are "McDyer v Celtic Football Club" and "McQueen v The Glasgow Garden Festival 1988 Ltd". Under United States common law, "res ipsa loquitur" has the following requirements:  Most American courts recognize "res ipsa loquitur". The Restatement (Second) of Torts, § 328D describes a two-step process for establishing "res ipsa loquitur". The first step is whether the accident is the kind usually caused by negligence, and the second is whether or not the defendant had exclusive control over the instrumentality that caused the accident.