As explained in Funk v. Carter, 2004 BCSC 866 at para. 22, even where a vehicle has the right of way, s. 181 imposes a duty on drivers to operate their vehicles in a manner that allows them to avoid pedestrians who are visible to them, and not unreasonably crossing their path of travel (such as "darting from between parked cars, or running, or possibly clothed so as to reduce visibility").
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