21. In general, where an allegation of deficient work is based on a claim that the work fell below the required industry standard, and the subject matter is outside ordinary knowledge, expert evidence is required to prove it. Other times, a breach of the standard may be so obvious that it does not require expert evidence: see Bergen v. Guliker, 2015 BCCA 283. For this perimeter drainage related work, I find the standard is not obvious and it requires expert evidence.
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