Several people with dogs have been injured in attacks by cows
Farmers have expressed disappointment and concern at a legal ruling in favour of a walker hurt when she was attacked by cows as she crossed a field.
Shirlie McKaskie was seriously hurt in Cumbria in 2003 and a judge has ruled the farmer was liable because he had not properly considered the risk.
Ms McKaskie is claiming £1m damages but farmer John Cameron is appealing.
Dairy farmers said so many fields were open to walkers that such incidents would occur from time to time.
The vice chairman of the Royal Association of Dairy Farmers, David Cotton, expressed his disappointment at the ruling.
"The number of footpaths we've got across this country - and more and more access is being made available to walkers - it's one of those situations that's going to occur from time to time," he said.
David Blunkett: 'The next thing I knew the cow had hit me.'
"I mean there are some parts of the country now where [farmers] can no longer put cattle in fields because the footpaths are used so much.
"If you think around some of the larger towns where footpaths are on the edge of towns, some of those fields they've already had to take cattle out of."
Vet death
Legal sources say the Preston Crown Court judge's decision in favour of Ms McKaskie, who was walking her dog at the time of the May 2003 attack and was rescued by Mr Cameron, could set a legal precedent and mean farmers having to remove their cattle from fields.
But the National Farmers' Union said there was nothing in law to prevent farmers putting cattle and calves in fields with public footpaths.
Robert Shearsby, from the union, said: "It is a concern that following a recent court case in light of the accident that there is a suggestion cattle should not be grazed in fields with footpaths.
"The NFU advises its members on the requirements of the law and what should be done to minimise risks."
The ruling follows a series of cattle attacks on walkers and their dogs, one of which proved fatal.
Last month former Home Secretary David Blunkett was injured by a charging cow while out walking with his guide dog Sadie in the Peak District.
The Sheffield MP suffered a broken rib and "painful bruising" but was well enough to attend a Labour Party meeting later.
The incident was followed by the death of vet Liz Crowsley, 49, from Warrington, who was trampled by a herd of cows.
Police believed the cattle became aggressive after seeing Ms Crowsley's two dogs on the Pennine Way, outside the village of Gayle, near Hawes, in the Yorkshire Dales.
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