Under s 25 of the Companion Animals Act 1998 (NSW), a dog owner is liable for indirect wounding where the dog's aggression causes a horse to shy and throw its rider, even without direct physical contact between the dog and the injured person. The actions of a dog running at a horse barking aggressively constitute an 'attack' rather than mere 'chasing'. An assessment of non-economic loss at 30% of a most extreme case for fractures to the wrist, elbow and possible shoulder blade, with pre-existing conditions and retained work capacity, was held to be wholly erroneous; 22% was substituted.
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