I agree with the conclusion of Arnold-Bailey J. in Callan v. Cooke, 2012 BCSC 1589 at para. 68, that the case law establishes that absent limited exceptions, the police do not owe a private law duty of care to victims or potential victims in relation to their investigations. The duty of the police to carry out proper investigations is a duty they owe to the public rather than to an individual victim or victim’s family.
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