What is the test for proving liability for a fire?

Saskatchewan, Canada


The following excerpt is from Denys v. Gabel, 2003 SKPC 97 (CanLII):

As noted in the chapter concerning liability for fire in Fleming on Torts, 8th edition (1992), "Failing Rylands v. Fletcher, the plaintiff is remitted to proving negligence". The plaintiffs' Statement of Claim alleges negligence, as well as strict liability.

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