An occupier of premises with automatically-opening gates or doors is not required to warn entrants that the gate may not open, as such gates are obvious obstacles whose operation is within the range of expectations of potential entrants. In warning sign cases, the plaintiff bears the burden of proving that a warning would have been seen, read, and would have modified behaviour to avoid injury; this cannot be inferred where no evidence is led about the nature, wording, placement or likely effectiveness of the warning, particularly where the plaintiff was distracted at the time of the incident.
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