A small recreational club with limited rights over public land, limited membership and resources, and which uses the site infrequently, may reasonably rely on adult visitors exercising due care for their own safety when engaging in obviously dangerous recreational activities. The scope of the duty of care owed by such a club is significantly limited by its restricted control, resources, and the nature of the site. The obviousness of the risk is a significant factor in the Shirt calculus that may lead to the conclusion that the reasonable response to the risk was to do nothing. The case also clarifies that occupier status requires some degree of actual or notional control, and a club with no power to exclude the public may not be an occupier in the legal sense.
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