There is no special or different duty imposed on a following or overtaking vehicle other than the duty owed by all road users to exercise reasonable care. Cases suggesting a 'special relationship' between leading and following vehicles provide guiding factors only, with every case determined on its own facts. An apportionment of 90/10 against a driver who failed to check mirrors, failed to indicate until immediately before turning, and turned sharply across the path of an overtaking vehicle was upheld as open and not plainly unjust.
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