Limits have been placed on the class of plaintiffs to whom a duty is owed. In Haig v. Bamford et al., 1976 CanLII 6 (SCC), [1976] 3 W.W.R. 331; 9 N.R. 43 (S.C.C.), liability could not be placed on an accountant for a negligently prepared financial statement, unless he or she had actual knowledge of the limited class of plaintiffs who would use and rely on the statement.
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