In assessing factual causation where the defendant's breach consists of failing to provide information to a professional, the court must determine what the professional would have done with the information, having regard to the scope of the professional's retainer. Where expert evidence diverges on what a competent professional would have done, the court may prefer the opinion that confines the professional's response to the scope of the retainer rather than requiring a broader safety audit. The question of what a hypothetical vibration expert would have found is a factual question on which the plaintiff bears the onus. Leave to argue a fundamentally different basis of liability on appeal will be refused where the relevant facts were not fully found at trial and the respondent would be prejudiced.
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