A cleaning contractor engaged by an occupier to keep premises safe owes a duty of care to persons coming onto the property, at least in relation to the creation of risk of injury, and this duty may extend to dealing with hazards created by others. However, where the terms of the cleaning contract have been varied and the evidence does not establish the contractor's specific obligations post-variation, breach of duty cannot be established. The question of whether a cleaning contractor's duty extends to failure to detect hazards created by others (as opposed to creating hazards) was left open by Gyles AJA.
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