What is the test for negligence in relation to training and supervision in high speed pursuits?

The allegation of negligence in relation to training and supervision requires the establishment of a duty of care, and a comparison of the defendants' conduct measured against the appropriate standard. The onus is on the plaintiff to establish all elements of the negligence alleged against the defendants. In Doern v. Phillips Estate (1994), 2 B.C.L.R. (2d) 349 (B.C.S.C.), Kirkpatrick J. reviewed a number of cases alleging negligence against police officers arising from the conduct of the police in high speed pursuits. Her Ladyship said, "Based on the authorities provided, there is little doubt that the standard of care to which a police officer will be held is that of the reasonable police officer, acting reasonably and within the statutory powers imposed upon him or her, according to the circumstances of the case."