Can an employer be held liable for the theft of an actor's overcoat?

Saskatchewan, Canada


The following excerpt is from Tremear v. Park Town Motor Hotels Ltd., 1982 CanLII 2683 (SK QB):

In Deyong v. Shenburn, the plaintiff, an actor, entered into a contract with the defendant, a theatrical producer, to play a part in a pantomime. During a rehearsal the plaintiff left his overcoat and other items in his dressing room and they were stolen. The plaintiff sought to attach liability to the defendant on three grounds: (i) Bailment; (ii) That it was an implied term of the contract that the defendant was under a duty to take reasonable steps to protect the property of the plaintiff from theft; and (iii) That the duty of an employer to provide a proper system of working extended to taking reasonable steps to protect the property of an employee from theft.

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