In negligence claims arising from violence on licensed premises, a plaintiff must establish not only that the defendant breached a duty of care but also a specific causal connection between the breach and the injury. The fact that injury occurred within an area of foreseeable risk does not relieve the plaintiff of the burden of proving causation. Trial judges must identify with precision the manner in which duties were breached and what steps, if taken, would have prevented the harm. The sudden emergency principle applies to the assessment of breach of duty by defendants, not only to contributory negligence.
The full text is available to signed-in members, including the 10 later cases that cite this judgment.