full exclusion of liability. Also, the person consenting to an act may not always be negligent: a bungee jumper may take the greatest possible care not to be injured, and if he is, the defence available to the organiser of the event will be volenti, not comparative negligence. Consent to medical treatment or consent to risky sports on the part of the claimant excludes liability in tort where that consent is informed consent. Other jurisdictions The Scots law of delict similarly recognises the principle and defence of volenti non fit injuria. US tort law has a similar legal principle known as assumption of risk. In Canada, the "volentio" principles applies in much the same way as under English law. The leading Canadian cases on point are Dube v. Labar, [1986] 1 SCR 649 and Hall v. Hebert, [1993] 2 SCR 159. Cases Trespassers The Occupiers' Liability Act 1984 (and in Scotland the Occupiers' Liability (Scotland) Act 1960) requires all owners of property to take reasonable steps to make their premises safe for anyone who enters them, even those who enter as trespassers, if they are aware of a risk on the premises. However, the doctrine of volenti has been applied to cases where a trespasser exposed themselves deliberately to risk: Titchener v British Railways Board [1983] 1 WLR 1427 Ratcliff v McConnell [1997] EWCA Civ 2679 Tomlinson v Congleton Borough Council [2003] UKHL 47 In the first case (decided before the Occupier's Liability Act was passed), a girl who had trespassed on the railway was hit by a train. The House of Lords ruled that the fencing around the railway was adequate, and the girl had voluntarily accepted the risk by breaking through it. In the second case, a student who had broken into a closed swimming-pool and injured himself by diving into the shallow end was similarly held responsible for his own injuries. The third case involved a man who dived into a shallow lake, despite the presence of "No Swimming" signs; the signs were held to be an adequate warning. Drunk drivers The defence of volenti is now excluded by statute where a passenger was injured as a result of agreeing to take a lift from a drunk car driver. However, in a well-known case of Morris v Murray [1990] 3 All ER 801 (Court of Appeal), volenti was held to apply to a drunk passenger, who accepted