The Makita test — that steps are slippery only if persons walking on them with ordinary care will from time to time slip — is confined to the particular circumstances of that case and is not a universal prerequisite for establishing slipperiness. Steps may be found to be excessively slippery based on expert evidence of non-compliance with Australian Standard 3661.1 (coefficient of friction), even where there is no prior history of falls on the specific steps. The absence of prior incidents is relevant but not determinative of whether an occupier has taken reasonable care.
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