The significance of the enhanced proximity of social hosts to their own guests was highlighted in a decision of this court dismissing a summary judgment motion for injuries sustained by a guest at a drinking party after he left the party. (See Wardak v. Froom, 2017 ONSC 1166 (CanLII), 38 C.C.L.T. (4th ) 166.) This case recognized that the law in the area of social host liability is still developing and noted that it was significant that the plaintiff was a guest, not a third-party (at paras. 51 and 52):
In terms of foreseeability and proximity, a host’s relationship with a guest is likely closer than the relationship between a host and a third party: Kim v. Thammavong,  O.J. 4769, 2007 CanLII 52791 (S.C.J.), at para. 25.
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