The parent of a minor child who is injured by the wrongful or negligent act of another cannot recover for the injury as such, because that right of action belongs to the child.9 The parent may, however, recover for any loss sustained by him in consequence of the injury to the child.10 The right of action in such cases is founded not on the parental relation but on the technical relation of master and servant, the recovery being on the theory of the loss of services.11

Such right may be destroyed by the contributory negligence of the father. The mother can only recover for personal injuries to the child after the death of the father.

Where a parent permits a child to work for an employe he assumes the ordinary risks of the employer's business and can only recover for injuries reached through causes outside of such ordinary risks. The limit of recovery by parent for injuries to child will be the actual loss to the parent, which may include the loss of the services of the child and the trouble and expense to which the parent was put in caring for the child. It may include prospective as well as past damages, but the prospective damages for the loss of services can only be for the value of the services of the child up to the age of twenty-one years. Under the common law the parent had no right of recovery for the death of his child; such a right was first given him by Lord Campbell's act.