An occupier of licensed premises who creates a potentially dangerous situation by selling liquor to large numbers of patrons at nocturnal entertainment, and who engages crowd controllers in recognition of that danger, owes a duty of care to police officers summoned to the premises to deal with disorder arising from the occupier's failure to maintain order. The American 'fireman's rule' — which would preclude recovery by emergency service personnel injured by the very hazard they are employed to address — does not form part of Australian law. The Modbury principle (no duty to prevent harm from criminal conduct of third parties) does not apply where the occupier has the ability to control the offending person on its own premises.
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