by the will of the parties. A party can seek to limit or exclude their obligations in tort (e.g. negligence) by way of an exemption clause. In Canada Steamship Lines Ltd v R (1952) AC 192, the Court held that where a clause expressly exempts a party from liability for negligence, effect must be given to the clause and liability excluded. s2(1) of the Occupier's Liability Act 1957 allows an occupier to 'exclude his duty to any visitor or visitors by agreement or otherwise'. In conclusion, whilst it is true that when parties enter into a contract they do so voluntarily, the terms of the contract may be limited, excluded, reinterpreted, implied into and construed by the Court in a way not comprehended by the parties. It cannot therefore be said that all 'obligations are created by the parties to the contract'. Similarly, in tort, situations are willingly entered into by parties and obligations fixed by law can be limited or excluded altogether and so the level of duty is 'fixed by the parties' to an extent. Both contract and tort are subject to an objective test of reasonableness applied by the Courts. Interestingly, the High Court of Canada has observed that there is no distinction between contractual obligations implied into a contract and obligations in tort. Both amount to "an objective expectation defined by the Courts of the appropriate obligation and the correlative right" (British Columbia Hydro and Power Authority v BG Checo International Ltd (1993) 99 DLR (4th)