it was reasonably foreseeable that harm could result from the defendant's actions. If so, the Court then applies a 'salient features' test to determine whether the plaintiff is owed a duty of care. Some of the salient features which the Court considers in making this inquiry include: Whether imposition of a duty of care would lead to 'indeterminate liability' – that is, it would interfere with the legitimate protection or pursuit of an individual's social or business interests. Whether imposition of a duty would constitute an unreasonable burden on individual autonomy. The degree of vulnerability of the plaintiff to the defendant's actions – their ability to guard against the harm. The degree of knowledge which the defendant had about the probability and likely magnitude of harm to the plaintiff. Special rules exist for the establishment of duty of care where the plaintiff suffered mental harm, or where the defendant is a public authority. To establish a duty of care, the plaintiff has to satisfy the requirement of CLA Act ss 27–33. In light of this, a large number of individuals cannot claim injuries as well. Meanwhile, compared to the ‘No-Fault Compensation’ system in New Zealand, the cost to claim injuries is much higher. In light of this, individuals especially the victims who lack knowledge or capability may choose not claim private nuisance after balancing the burden and outcomes. This view affirmed by Regina Graycar, he states that the courts in Australia are reluctant to award damages for personal injuries. In New South Wales, a plaintiff is able to recover for non-economic loss, including pain and suffering, loss of amenities/expectation of life and disfigurement, upon the severity of the loss being at least 15% of 'most extreme case'. As of October 2016, NSW Attorney General, Gabrielle Upton, has updated the maximum amount of damages for non-economic loss from $594,000 to $605,000. France On 27 March 2017, the French National Assembly adopted a law entitled “Devoir de vigilance des entreprises donneuses d'ordre”, whose title has been translated into English as a "duty of vigilance" or "duty of care". The law will oblige large French companies (companies with at least 5,000 staff in France or 10,000 staff within their combined French and foreign offices over two consecutive years) to: "Establish and implement a diligence plan which should state the measures taken to identify and prevent the occurrence of human rights and environmental risks