The practice of a profession, art or calling which demands a special skill or ability carries with it a duty to exercise a reasonable amount of skill or ability. Before 19631 it was thought that where a person failed to use such reasonable skill or ability he was liable for breach of contractual duty2 only and was not under a general duty in tort unless the failure was likely to cause physical injury to persons or property3. After 1963 it was at first assumed that this continued to be the case
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