Can a commercial host be held liable for failing to prevent a customer from taking a positive action?

In Stewart v. Pettie (supra at page 146), Major, J. points out that while the courts have historically been reluctant to impose liability for a failure by an individual to take positive action, this reluctance has been tempered where there is a special relationship between the parties that warrants the imposition of a duty. Major, J. found that every person who enters a bar or restaurant is in an invitor-invitee relationship, and therefore in a special relationship with the establishment. He did not accept, however, that the mere existence of this special relationship without more permits the imposition of a positive obligation to act, or, in other words, a duty. He suggested that a commercial host can consider other relevant factors in determining whether in the circumstances positive steps are necessary.