The 'known uncertainty' approach to reasonable foreseeability approved in CSR v Young (adopting Fitzgerald P in Bale v Seltsam) does not extend to permit a finding of foreseeability based on mere speculation about risks not yet identified by the medical or scientific community. There must be some level of appreciation at the relevant time that the particular type of exposure carried real risks; the fact that the level of uncertainty was inconsistent with affirmative rejection of a causal link is insufficient. References to 'transitory', 'minimal' or 'slight' exposure in medical literature must be understood in their context and cannot be extrapolated to cover qualitatively different types of exposure.
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