Speaking about the duty of care in Michael and Others v Chief Constable of South Wales Police and Another [2015] UKSC 2, Lord Toulson remarked that ‘[f]rom time to time the courts have looked for some universal formula or yardstick [for determining whether a duty of care is owed], but the quest has been elusive’ [103].
To what extent do you agree with Lord Toulson’s remark about the evolution of the duty of care?
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