The risk of trees falling in a forest, at any rate in high winds, is an obvious danger that an occupier of a forest reserve is entitled to expect adult visitors to appreciate. A duty to erect warning signs about endemic natural hazards in a forest environment is unlikely to arise where the tree in question was not individually 'hazardous' (i.e., posing a known or obvious risk of falling in the immediate or short-term future). In failure-to-warn cases, a plaintiff must establish not merely that they would have 'taken notice' of a warning, but that they would have taken a specific course of action that would have avoided the injury.
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