What is the standard for a ski instructor to be found guilty of reckless disregard for the safety of another skier?

It is my opinion that if a skier decides to ski in a fashion that makes it difficult or impossible to remain in control, then that skier has violated the obligation imposed upon all skiers to try to remain under control. Thus, it seems to me that the violation of the duty of care imposed upon skiers usually involves an element of heedlessness for the safety of others. In the leading case of Fink v. Greeniaus, supra, my sister Van Camp came to a similar conclusion. I am in agreement with the standard which she found to be applicable in that case. At p. 549 O.R., p. 493 D.L.R., she said that: ". . . the defendant skier owed a duty of care to his fellow-skier not to act in reckless disregard of the other's safety".