The impact of the Supreme Court of Canada's decisions in Bazley v. Curry [1999] 2 S.C.R. 534 and Jacobi v. Griffiths [1999] 2 S.C.R. 570 continues to be felt across the common law world.

In those cases, the Supreme Court ruled that an employee's tort would be held to have been committed in the course of her employment if there was a “sufficiently close connection” between the employee's tort and what she was employed to do to make it “fair and just” that the employer should be held vicariously liable for the employee's tort. The Supreme Court went on to rule that such a connection would exist if and only if the work the employee was employed to do created or increased a risk that the employee would commit the kind of tort that she committed.