Does a skid on a highway result in a finding of negligence?

Whether a skid on a highway results in a finding of negligence depends on the circumstances of the case. In Browne v. De Luxe Car Services, [1941] 1 K.B. 549 it is stated at p. 553: ..........The degree of care which is called for from a driver depends upon the circumstances of the case. A driver who is proceeding along a piece of road which he knows to be slippery has imposed upon him the burden of driving with an extra degree of care. Certain manoeuvres upon such a road would no doubt be dangerous, and any prudent driver would know that they were dangerous. A sudden alteration of direction, a sudden application of brakes, driving in such a way that one or other of those two manoeuvres may suddenly become necessary – all those are things which the prudent driver must avoid; but if a driver upon a road, which he knows to be slippery, is driving with that measure of care which, in ordinary circumstances, would be perfectly safe upon such a road, he is not to be found guilty of negligence because, for some reason or another, an accident takes place owing to a skid.

Browne v. De Luxe Car Services, supra, was referred to by Macdonald, J.A. in Grant v. Lutes, supra, who stated at ¶ 59: .............in motor vehicle accident cases, if the driver can establish that he was driving with the ordinary care, caution and skill which a driver is required to exercise under the conditions as they existed at the time of the accident he is not to be found guilty of negligence because for some reason or other, an accident takes place owing to a skid. In other words, if he proves that he met the foregoing standard of care he has established or shown ‘a way in which the accident may have occurred without negligence.’