In Port Coquitlam (City) v. Wilson 1922 CarswellBC 109; 1922 CanLII 17 (SCC), [1923] 1 W.W.R. 1025 (S.C.C.), Duff J. (as he then was) concluded that an obligation to take reasonable precautions in dealing with such a dangerous element as fire is an obligation to take special care. Duff J. cited as authority for his conclusion Filliter v. Phippard supra, a case involving a rural fire. I am of the opinion that his conclusion in Port Coquitlam has application to the present case.
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