A public authority controlling a natural reserve to which the public has a right of access owes a duty of care measured according to the nature of the premises, but where the danger is a natural feature that is apparent and known, and the risk is equally foreseeable to the visitor, the authority is not in breach by failing to take positive steps such as fencing, lighting or signage. Policy considerations relating to resource allocation across extensive natural areas further militate against imposing such a duty. Causation may also fail where the plaintiff had already passed beyond existing barriers and it cannot be shown that additional measures would probably have prevented the injury.
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