What is the test for rescuers to be awarded damages for injuries sustained by rescuers in a motor vehicle accident?

The requirement that there be some imminent danger is perhaps best illustrated by the discussion in Haynes v. Harwood, supra—one of the earlier cases granting a rescuer damages. In that case, the defendants’ servant had negligently left his horses and van unattended on a busy street and the horses bolted. A police officer saw the runaway horses and, eventually, stopped them. However, he sustained serious injuries in the process. The defendants pleaded volenti non fit injuria and novus actus interveniens.