Negligence - nature of common law duty in respect of highways - motor vehicle collision on toll road due to presence of smoke from fire on adjoining lands - whether concessionaire of toll road who had contracted out obligation for operation and maintenance to a third party had a duty of care to the user of the highway at common law
Breach of Contract - whether there is evidence of contract.

<p>Negligence - Personal Injury - Liability for dogs based on a breach of duty of care - Whether the defendant owed the claimant a duty of care in relation to dog(s) on its premises – Whether the claimant was a trespasser - quantum of damages Whether Reply contains new causes of action not pleaded in the particulars of claim-application to amend claim form and particulars of claim after close of claimant’s case - CPR 8.9(1), 10.9</p>