In Stokes v Guest, Keen and Nettlefold (Bolts and Nuts) Ltd  1 WLR 1776, it was held: that an employer does not fall below the standard to be properly expected of a reasonable and prudent employer if it follows a recognised practice, unless it is clearly bad, but it must keep reasonably abreast of developing knowledge, and not be too slow to apply it; that where an employer has greater than average knowledge of the risks it might be obliged to take more than average precautions; and that it should weigh up the risk in terms of the likelihood of injury occurring and the potential consequences and balance that against the effectiveness, expense and inconvenience of the precautions.
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