Liability For Deficient Street Lighting In A Motor Vehicle Collision

What results when a faulty streetlight causes or contributes to a motor vehicle collision?  Where reduced lighting decreases visibility in the area, there may be a liability on the authority responsible for maintaining the streetlight.  These two cases are instructive.

In Meghji v Lee, 2011 BCSC 1108, the Province of British Columbia was found 10% liable for deficient lighting in a pedestrian-vehicle collision where the driver was found 90% liable.  The Province's liability was based on its placement of luminaries (i.e. streetlights) which decreased the amount of light available at the intersection and hence increased the uniformity ratio.  According to the Court of Appeal for British Columbia—which upheld the trial judge's findings on liability—keeping the uniformity ratio low reduced the time it took the eye to adjust to changes in lighting: