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SCC
R. v. Javanmardi, 2019 SCC 54, [2019] 4 SCR 3
As with the assessment of conduct in cases of criminal negligence, the assessment of fault by the trier of fact is entirely contextual. ... Certain activities, for example, require special attention and skill. ... I note, for example, the conduct set out below, on which the Court of Appeal relied in finding a marked departure. ...