In negligence by omission cases, even where breach of duty is established, the plaintiff must still prove on the balance of probabilities that the omitted precaution would have avoided the specific injury suffered. Where the plaintiff's evidence as to the circumstances of injury is found unreliable, and the injury may have occurred during a phase of activity not caused by the breach (here, non-compliant manual handling contrary to a known no-lift policy), causation is not established. The case also confirms that the inquiry into whether an omitted precaution would have avoided the incident must focus on the incident that actually occurred, not on speculative alternative scenarios.
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