It would be reasonable for the garage to ask how you allowed it to overheat to the stage that it was hot enough to crack the head, if indeed that was the sequence of events.
It would be very difficult for a court (or expert) to say whether the head was weakened long ago leading to needing a gasket replaced. The work could well have weakened it some more and eventually it just gave out. It would be very difficult to prove negligence against the garage in this case in my view.
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