What is the current state of the law on liability for injuries sustained by a seated passenger on a bus?

The majority of the authorities cited by counsel analyze the issue of liability in circumstances where the passenger was embarking, disembarking, standing or walking on the aisle when the injury occurred. One decision placed before me that deals with a seated passenger is Sarkar v. Sarai, [1993] B.C.J. No. 3203, on which the defendants rely heavily. In Sarkar, as the driver rounded a curve on the route, the female passenger suddenly slid across her seat and fell onto the floor. Her little son, who had been asleep on her lap, fell on top of her. The trial judge did not accept as accurate the plaintiff’s impression that the bus had been travelling faster than usual as it negotiated the curve, finding instead that the driver took the curve at his normal speed.