What is the current state of the law of negligence between prison guards and prisoners?

Canada (Federal), Canada

The following excerpt is from Carlson v. Canada, 1998 CanLII 8109 (FC):

With respect to a cause of action in negligence, there is no doubt that the guards owed a duty of care to the plaintiff. Cullen J., in Abbott v. Canada2, commented as follows on the relationship between guards and prisoners in the law of negligence:

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