In Planidin v. Dykes,  B.C.J. No. 907 (S.C.) McLachlin J. (as she then was) found the defendant bus driver was liable for injuries to the plaintiff who fell when the bus was put in motion with a “sudden jerk” as the “obviously” elderly plaintiff, who was “laden with parcels”, was beginning to walk down the aisle of the bus after having paid her fare. There were only two other passengers on the bus at the time and nothing to distract the driver, who was on schedule and therefore in no particular hurry.
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