Lord Macmillan has said that the categories of negligence are never closed, so that our actions must be non-negligent with respect to a potentially expanding range of interests. What are the advantages and disadvantages of this approach to tort law? Cases illustrating the expansion of liability for negligence include Donoghue v. Stevenson [1932] AC 562, City of Kamloops v. Nielsen [1984] 2 SCR 2, and Canada National Railway Co. v. Norsk Pacific Steamship Co. [1992] 1 SCR 1021
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