Is expert evidence required to establish the standard of care of an insurance adjuster?

On the question of whether expert evidence is required to establish the standard of care of an insurance adjuster, I note there is authority to the effect that “matters falling within the ordinary common sense of juries can be judged to be negligent”:ter Neuzen v. Korn, 1995 CanLII 72 (SCC), [1995] 3 S.C.R. 674, 1995 CarswellBC 593, at para. 57. On the question of whether expert evidence was necessary to establish the standard of care, the court in Meehan cited Shaak v. McIntyre, 1991 CarswellBC 1783, where Ryan J., at para. 51 said that, "[t]here may be cases where the defendant has so clearly fallen below the standard required of him or her that expert evidence is not required." Such a case, the court in Meehan said at para. 37, “would entail a particularly egregious act or omission, such that an ordinary person would easily be able to recognize the negligence.” However, as noted above, the court went on to find, at para. 39, that “the standards of conduct of the professional in question are not in the ordinary experience of a judge or lay person.”