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Cf Andrew Simester, ‘Can Carelessness Feel Culpable’ inside the Jeremy Horder (ed), Oxford Essays toward Jurisprudence: next Show (2000) 88-90 (23) Pyrenees Shire Council v-day (1998) 192 CLR 330, 389 (Gummow J); Graham Barclay Oysters’ Ply Ltd v Ryan (2002) 211 CLR 540, 577 (McHugh J), 630-step 3 (Kirby J); Crimmins v Stevedoring Community Money