20. The respondent can prove a breach of contract if she establishes that the applicant breached the standards expected of a competent painter. However, if the conduct in question is of a technical or scientific nature or otherwise outside the knowledge and experience of the ordinary person, then expert evidence of the standard of care, its content, and breach, will likely be necessary: Bergen v. Guliker, 2015 BCCA 283 at paragraph 119. This is because the standards of an industry are often outside of the knowledge or expertise of an ordinary person.
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