In Deyong v. Shenburn, the plaintiff, an actor, entered into a contract with the defendant, a theatrical producer, to play a part in a pantomime. During a rehearsal the plaintiff left his overcoat and other items in his dressing room and they were stolen. The plaintiff sought to attach liability to the defendant on three grounds: (i) Bailment; (ii) That it was an implied term of the contract that the defendant was under a duty to take reasonable steps to protect the property of the plaintiff from theft; and (iii) That the duty of an employer to provide a proper system of working extended to taking reasonable steps to protect the property of an employee from theft.
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