The Naxakis causation framework (increased risk plus materialisation of risk permits inference of causation) applies in medical negligence cases where the evidence goes beyond mere statistical or epidemiological possibility to evidence specific to the plaintiff's circumstances. The defendant bears only an evidentiary burden to point to evidence suggesting no causal connection, not a legal burden of proof. The Seltsam limitation on the Naxakis framework is confined to cases where the evidence consists almost exclusively of epidemiological studies establishing only a statistical possibility.
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