An occupier's failure to clip grass around a concealed depression on a commonly used pathway on a golf course can constitute a breach of the duty of care owed to golfers, including where the immediate cause of injury is a third party's overreaction to the hazard. An overreaction by a third party to a sudden and unexpected situation created by the defendant's breach does not break the chain of causation where the whole transaction occupies only a few seconds. The Victorian Court of Appeal split on whether a 60/40 apportionment against the occupier (versus the cart driver) was within the permissible range.
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