In pedestrian tripping cases involving night-time incidents, the plaintiff bears the burden of proving that the hazard was not obvious to a pedestrian exercising reasonable care, including by adducing evidence of the state of illumination and visibility at the time. The absence of evidence about lighting conditions at night is fatal to the plaintiff's case where the hazard is obvious in daylight. The obviousness of a risk to a careful pedestrian preferably goes to breach of duty rather than the existence of a duty of care.
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