Kay's Tutor v. Ayrshire & Arran Health Board [1987] 2 All ER 417; 1987 S.C. 145; 1987 S.L.T. 577; is a Scots Delict Law case concerning causation in a medical negligence context. It was decided by the House of Lords, with Lord Keith of Kinkel, Lord Brandon of Oakbrook, Lord Griffiths, Lord Mackay of Clashfern and Lord Ackner sitting.