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#duty #law #negligence #tort
The initial reservation with the Anns approach was voiced by the Australian judge Brennan J in Sutherland Shire Council v Heyman (1985) 60 ALR 1. In Sutherland Brennan J. stated:

It is preferable, in my view, that the law should develop novel categories of negligence incrementally and by analogy with established categories rather than by a massive extension of a prima facie duty of care restrained only by indefinable considerations which ought to negative or reduce or limit the scope of the duty or the class of person to whom it is owed.

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