Can a hockey player be held liable for physical contact with another player in a game?

Physical contact is inherent in some sports, such as hockey. Players can be taken to consent to a certain level of contact and to accept the risks of that contact, unless the conduct falls outside the scope of such presumed consent. As observed by Cunningham J. in Dunn v. University of Ottawa, [1995] O.J. No. 2856 (C.J.), at para. 14, “Even if contact is made outside the rules of the game, there can be no liability unless the player can establish that the Defendant knew he was breaking the rules, and had formed a deliberate resolve to injure or that he was reckless as to the consequences of his actions.”