The effect of s. 174 is to cast the burden on the left turning driver to prove the absence of an immediate hazard at the moment the left turn begins. Thus, if a left turning driver asserts that he or she started to turn when it was safe to do so, then the burden of proving that fact rests with him or her: Nerval v. Khehra, 2012 BCCA 436 [Nerval] at paras. 33-35.
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