Where an employer's breach of duty consists of providing a system of work that contemplates an employee securing premises alone, and the employee is injured by a criminal act during that process, the causal link may be sufficiently obvious that no elaborate explanation of causation is required in the trial judge's reasons. A broad-brush assessment of future economic loss that does not disclose the basis of calculation will be set aside. Under R.S.C. 64.23(5), a retrial may be ordered on economic loss generally (both past and future) even where only future economic loss was challenged, to achieve a consistent result. The court left open the question whether causation in third-party criminal act cases requires proof that injury would have been averted, or merely that the risk would have been substantially diminished.
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