FRONEMAN J answer to the duty question should already have been dealt with in the primary enquiry to determine whether the employee‘s own conduct was wrongful, a determination upon which the secondary, vicarious, liability of the employer, traditionally understood, depends on. [105] The explanation for the apparent overlap between direct and vicarious liability is, however, not only that it has suddenly been brought upon us by the decision in K, but rather that the distinction between direct and vicarious liability has never been as clear as traditionalists want us to believe. [106] In Vicarious Liability in the Law of Torts,24 Professor Atiyah remarks that the idea that a person is liable only for— ―acts or omissions—for things which he has actually done or omitted to do—is in many ways a dangerous and misleading half-truth. It would be more accurate to say that a person is generally liable for an event or an occurrence causing loss to the plaintiff, for which the defendant bears some measure of responsibility.‖25 [107] There are many situations in the law where that responsibility arises from the fact that defendants have played some role in creating the risk that caused the loss, or because they have in some way associated themselves with the risk by ―authorising, assisting or procuring its commission, or by ratifying it after it is done.‖26 Liability for omissions also makes the line between personal and vicarious liability less clear, 24 Above n 5. 25 Atiyah above n 5 at 3-4. 26 Id at 4. 42