Loud and boisterous behaviour by intoxicated patrons, including swearing amongst themselves in the presence of children, without any prior interaction with other patrons, aggressive gesturing, or indicia of physical violence directed at others, does not constitute 'disorder' or 'quarrelsome or disorderly conduct' sufficient to raise a foreseeable risk of violent assault requiring the operator of licensed premises to take additional precautions such as engaging specialist crowd controllers or refusing the group entry. The duty to make premises safe as a contractual entrant adds nothing where the steps taken already satisfy the standard of reasonable care.
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