DISSENTING OPINION OF
RICHARDSON, C.J.WITH WHOM SODETANI, CIRCUIT JUDGE, JOINS
I concur in the court’s holding that for the purpose of determining jurisdiction under Hawaii’s statute, a tort is committed where the injury occurs, and the phrase “tortious act” in HRS § 634-71(a) (2) encompasses the injurious consequences of an act.
I respectfully dissent from the court’s holding that the assertion of jurisdiction by Hawaii in this case would be a denial of constitutional due process of law.
In analyzing the due process requirements controlling state court jurisdiction over nonresident defendants, the basic consideration is fairness, and concern focuses not on where it is most desirable to bring suit but on whether minimum requirements of fairness are met. Hanson v. Denckla, 357 U.S. 235, 251, 254 (1958); Kurland, The Supreme Court and In Personam Jurisdiction of State Courts, 25 U. Chi. L. Rev. 569; 620-621 (1958).
International Shoe Co. v. Washington, 326 U.S. 310 (1945), remains the foundation of modern due process analysis of state court in personam jurisdiction over nonresidents. In that case the Court stated that a defendant must have “minimum contacts” with the forum state “such that the maintenance of the suit does not offend ‘traditional notions of fair play and substantial justice.’ ”326 U.S. 310, 316. The Court advocated a case-by-case analysis in examining “the quality and nature of the activity in relation to the fair and orderly administration of the laws which it was the purpose of the due process clause to insure.” 326 U.S. 310, 319.
Some later cases and commentaries propose different approaches and formulations of when jurisdiction is proper, *315but fundamentally they attempt to determine when the assertion of state court jurisdiction is fair.1 The trend of later cases has been to enlarge the constitutional scope of state court jurisdiction,2 and some state statutes have followed that expansion by broadening jurisdiction to the constitutionally permissible limits. Gray v. American Standard Radiator, supra. On the other hand, Hanson v. Denckla, supra, 357 U.S. 235 (1958), limits the scope of that expansion by admonishing that, “It is essential in each case that there be some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum State thus invoking the benefits and protections of its laws.” 357 U.S. at 253.
Turning toward specifics, we note that not only do Gray and Duple Motor Bodies, the product liability cases discussed above in which the only contact with the forum state is the injurious consequence of the alleged negligence, fall within *316the relevant statutory provisions, but the assertion of jurisdiction in those cases has been held to comply with the constitutional requirements of due process. Gray v. American Radiator, supra; Duple Motor Bodies, Ltd. v. Hollingsworth, supra. There is no general distinction between product liability and malpractice cases for the purposes of due process analysis. Compare Duple Motor Bodies, supra, and Jones Enterprises v. Atlas Service Corp., 442 F.2d 1136 (9th Cir. 1971). Certainly there is no general distinction between the possible severities of injuries. Fatality from an auto accident may result from either defectively made brakes or improperly prescribed drugs. Nor can it be said that the consequences of negligence differ in foreseeability with the type of tort. Neither are the number of contacts required for due process different; a single contact may suffice. Compare Duple Motor Bodies, supra with Jones Enterprises, supra. Defendant-appellee, however, argues that Duple and Jones, supra, are distinguishable while Wright v. Yackley, 459 F.2d 287 (1972) is on point and compels affirmance of the trial court.
In Wright v. Yackley, supra, a South Dakota physician treated and prescribed medicine for a South Dakota resident. The patient moved to Idaho and four months after her last treatment sought to have the prescription refilled in Idaho, at which time the druggist sought confirmation of the prescription. The patient wrote to her doctor for said confirmation, and on this request and without charge the doctor mailed copies of the prescription from South Dakota to Idaho. The druggist was satisfied, filled the prescription, and the plaintiff alleged she was ultimately injured by the use of the prescribed drugs.
The Ninth Circuit Court of Appeals affirmed the district court judgment that Idaho could not exercise jurisdiction over the nonresident defendant doctor consistently with the constitutional requirement of due process of law. The appeals court stressed that in the personal service case focus must be on the place where the services are rendered, since this was thought to be the place of the receiver’s need. The court then enumerated three factors which made jurisdiction “un*317reasonable.” First, there was “no systematic or continuing effort on the part of the doctor to provide services which are to be felt in the forum state.” 459 F.2d at 290. Second, the nature of the contact with the forum was said to be “normally grounded outside any relationship with the forum state . . . residence of a recipient in the forum is irrelevant and incidental to the benefits provided by the defendant in his location. Third, the dominant state interest was found in its citizens’ free access to medical care when they travel out of state. 459 F.2d at 290-291.
The first argument about the number of contacts is puzzling in light of cases holding that a single contact may suffice to establish jurisdiction when the cause of action arises from the contact. See McGee v. International Life Insurance Co., 355 U.S. 220 (1957), and the Ninth Circuit’s own cases,Duple Motor Bodies, and Jones Enterprises, supra. In the latter two cases contact was not continuing and systematic.
The third point suggests an examination of all the interests involved. In this case the plaintiff and defendant are both individuals and have similar interests in the costs and inconveniences of litigating in a foreign state; neither is a corporation with vast financial resources. Hawaii has several interests: an interest in the availability of medical services for its travelling citizens, an interest in securing redress for its citizens injured within its borders, and an interest in interpreting its own substantive law. The State interest in interpretation arises because the place of the injury governs the substantive tort law, especially when the plaintiff is also a domiciliary in the state where he was injured, Restatement 2d, Conflicts § 146. We cannot say from observing this constellation of interests that exerting jurisdiction would be unreasonable or unfair as a matter of constitutional law. If the legislature believes that the availability of medical services to travelling Hawaii citizens is indeed the “dominant state interest,” then it retains the power to amend HRS § 634-71.
The constitutional issue narrows to the reasonableness or fairness of jurisdiction in light of the nature and quality of the nonresident defendant’s contacts with the forum state.
*318The Ninth Circuit has stated that “the existence of an effect in the forum state, cannot, without more, subject its cause to in personam jurisdiction in that state,” but has added that “very little indeed in addition to impact in the state is required to satisfy due process. ” Jones Enterprises, Inc. v. Atlas Service Corp., supra, 442 F.2d 1136, 1139 (9th Cir. 1971). In Duple Motor Bodies and Jones Enterprises, supra, “something more” was found. Wright v. Yackley, supra, refers to those cases in terms of “voluntary interstate economic activity . . . which is directed at various states in order to benefit from effects sought in those states. ’ ’ 459 F.2d at 290. In Wright v. Yackley, supra, however, foreseeability was the only element in addition to the effect of the act in the forum state, and the Ninth Circuit rejected foreseeability as a sufficient addition. See note 4, 459 F.2d at 289.
For the Ninth Circuit voluntary interstate benefit-seeking satisfies the requirement of Hanson v. Denckla, supra, 357 U.S. at 253, that the defendant “purposefully avails itself of the privilege of conducting activities within the forum state. ’ ’ As was stated in Jones Enterprises, supra, “the extent of purposeful submission to the laws of the forum state necessary to satisfy this requirement, however, depends upon the nature of the activity giving rise to the suit.” 442 F.2d 1140. Inspection of the Ninth Circuit’s own cases, Duple Motor Bodies and Jones Enterprises, supra, and of Gray v. American Radiator, supra, reveals very tenuous “purposeful submission.” In Duple and Jones the defendants clearly knew where their respective product or service was going, but the incorporation of the product or service into the products which were actually sent into the forum state occurred outside the forum state. In Gray the same incorporation situation occurred but without any showing that the nonresident defendant actually foresaw the eventual destination; instead, the court found that the defendant could reasonably have foreseen the eventual destination of the larger product in which its own product was incorporated. 176 N.E.2d 761, 766. The constitutionality of personal jurisdiction based on such tenuous connections undermines the strict application of Hanson v. Denckla in interstate tort cases (especially since Han*319son was not a tort case), and Hanson has been directly attacked in the product liability context, Phillips v. Anchor Hocking Glass Corp., 100 Ariz. 251, 256, 413 P.2d 732, 735 (1966).3 Similarly, our own reliance on Hanson in Gordon v. Granstedt, 54 Haw. 597, 513 P.2d 165 (1973), is distinguishable because Gordon was not a tort case either.
“Voluntary interstate economic activity” thus appears more important as an element of fairness than as an item to satisfy Hanson v. Denckla, supra.4 While the intent to benefit from the foreign consequences of one’s acts certainly makes jurisdiction by the foreign state fairer, especially when the acts are designed to produce the foreign consequences, we cannot say that such jurisdiction is unfair when there is no intent to benefit but the foreign consequences are nonetheless foreseeable. First, there is no argument that jurisdiction is improper if harmful consequences of an act are intended to be felt across state lines. The intentional firing of a bullet across a state line is a classic example. Leflar, American Conflicts Law 81 (1968). How much should it matter that the gun is negligently discharged? International Shoe reminds us to approach each case on its own facts, and our case involves the foreseeable use and consequences of drugs. Drugs are commonly recognized as containing considerable potential for harm, as well as for good, and unlike other products, drugs are totally beyond the power of the ordinary consumer to evaluate before using.5 Accordingly, both our national and state governments have legislated in several areas involving the quality, use, and handling of drugs. For example, HRS Chapters 328 and 329, Act 9, S.L.H. 1972 Ch. 12, Part IV. The nature of the item or service involved in the *320interstate contact definitely is a factor in evaluating the nature and quality of the defendant’s contact with the forum state. Second, the commercial contexts of product liability cases and the analyses dealing with the “doing business” provisions of long-arm statutes do not automatically control noncommercial cases.
While it definitely seems fair that one who seeks benefit from his or her contact with a foreign state should also bear the risks of that contact, it is equally well established that one of the major purposes of tort law, especially in the field of negligence, is to compensate injured parties for the wrongs of others, Restatement 2d, Conflicts § 146, pp. 432-3, and this too is considered eminently fair. That purpose is augmented in this case by Hawaii’s strong interest in providing redress for its own citizen who had absolutely no contact with the defendant’s state and yet was injured within the forum state,6 and by the state’s interest in interpreting its own substantive tort law. The point is not to confuse substantive tort law with jurisdictional law, but the purposes of the substantive law do influence jurisdictional considerations. Curtis Publishing Co. v. Birdsong, 360 F.2d 344 (5th Cir. 1966); Viernes v. Dist. Ct., 4th Jud. Dist., supra, 509 P.2d 306 (1973). See Restatement 2d, Conflicts § 36, Comment c; 37 Comment a, which indicates that the reasonableness of jurisdiction depends partly on the state’s interests. The purposes of substantive law are definitely among a state’s interests. And see also Carrington & Martin, supra, note 5.
If the defendant may be expected to answer for his negligence when the consequences of his act are geographically remote, then in certain cases he may be expected to answer for that negligence where the injury occurs. I hold that this is such a case.
I would reverse the decision of the trial court.
Aftanase v. Economy Baler Co., 343 F.2d 187, 197 (1965); Buckley v. New York Times Co., 338 F.2d 470 (5th Cir. 1964); Tyee Construction Co. v. Dulien Steel Products, Inc., 62 Wash. 2d 106, 381 P.2d 245, 251 (1963); Gray v. American Radiator and Standard Sanitary Corp., 22 Ill. 2d 432, 176 N.E.2d 761 (1961); Curtis Publishing Co. v. Birdsong, 360 F.2d 344 (5th Cir. 1966); Viernes v. Dist. Ct., 4th Jud. Dist., 509 P.2d 306 (1973).
Carrington & Martin, Substantive Interests and the Jurisdiction of State Courts, 66 Mich. L. Rev. 227 (1967); Comment, Long-Arm, and Quasi in Rem Jurisdiction and the Fundamental Test of Fairness, 69 Mich. L. Rev. 300 (1970); Currie, The Growth of the Long Arm: Eight Years of Extended Jurisdiction in Illinois, 1963 U. ILL. L. F. 533 (1963); Developments in the Law - State Court Jurisdiction, 73 Harv. L. Rev. 909 (1960); Hazard, A General Theory of State Court Jurisdiction, 1965 Sup. Ct. Rev. 241; Von Mehren & Trautman, Jurisdiction to Adjudicate: A Suggested Analysis, 79 Harv. L. Rev. 1121 (1966); Leñar, American Conflicts Law 12 (1968); Restatement 2d, Conflict of Laws, §§ 24, 27, 37.
United States Supreme Court: Travelers Health Ass’n v. Virginia ex rel. State Corp. Commn., 339 U.S. 643 (1950); Perkins v. Benguet Consol. Mining Co., 342 U.S. 437 (1952); McGee v. International Life Ins. Co., 355 U.S. 220 (1957).
For some review of cases, see Comment, Long-Arm and Quasi in Rem Jurisdiction, supra, note 5, Developments in the Law, supra, note 5; Currie, supra, note 5, Kurland, The Supreme Court, The Due Process Clause and In Personam Jurisdiction of State Courts, 25 U. Chi. L. Rev. 569 (1958); Reese & Galston, Doing an Act or Causing Consequences as Bases ofJudicial Jurisdiction, 44IowaL. Rev. 249(1959); 24 A.L.R.3d 532 at 541; 2 Moore, Federal Practice ¶ 4.25[3], [4].
Hanson has been criticized on other grounds. Hazard, A General Theory of State-Court Jurisdiction, 1965 Sup. Ct. Rev. 241, 244 (1965).
Keckler v. Brookwood Country Club, 248 F. Supp. 645, 649, clearly advances interstate commerce as the critical item of fairness.
Commentary, Conflict of Laws —Long Arm Jurisdiction —Mailing of Prescriptions Into Forum State Does Not Confer In Personam Jurisdiction Over Doctor in Another State, 24 Ala. L. Rev. 634, 644 (1972).
For discussion of the plaintiff’s and defendant’s relative scopes of geographical activity as an element of fariness, see Von Mehren and Trautman, supra, note 5.