Lex Pundit
BusinessSettled

The duty of care in negligence

A person owes a duty to take reasonable care not to harm those they can reasonably foresee being affected by their conduct.

Position current as of July 2026

Current position

Negligence liability begins with a duty of care. Its modern form comes from the “neighbour principle”: one must take reasonable care to avoid acts one can reasonably foresee would be likely to injure a person closely and directly affected.

For established categories of relationship, a duty is taken as settled. For novel claims, Canadian courts ask whether the harm was a reasonably foreseeable consequence and whether there was a relationship of proximity, and then whether wider policy reasons should nonetheless negate the duty.

Governing authority
Donoghue v Stevenson
[1932] AC 562 (HL)

Donoghue is the origin of the modern duty of care; Canadian courts test novel duties through a structured foreseeability-and-proximity analysis.

Key cases
House of Lords
Donoghue v Stevenson
[1932] AC 562 (HL) · May 26, 1932

A consumer who fell ill after drinking ginger beer said to contain a decomposed snail could sue the manufacturer despite having no contract with it. The House of Lords recognised a general duty of care in negligence, framed by the 'neighbour principle': one must take reasonable care to avoid acts likely to injure those one can reasonably foresee being affected.

How the law evolved
1932
Donoghue v StevensonOrigin
[1932] AC 562
The House of Lords recognises a general duty of care through the neighbour principle.
1978–2001
The structured testLeading cases
Foreseeability and proximity, then residual policy — the framework Canadian courts now use for novel duties.
Today
Category-based approach
Recognised relationships carry a settled duty; only genuinely new situations run the full analysis.