In the context of the debate over the reasoning in Rankin's Garage, readers might find interesting the Court of Appeal for Ontario's decision in 1688782 Ontario Inc. v Maple Leaf Foods Inc., 2018 ONCA 407 (available at http://www.ontariocourts.ca/decisions/2018/2018ONCA0407.htm).

The case deals with an alleged duty of care owed by a manufacturer of ready-to-eat meats to the franchisees of a sandwich restaurant (Mr Sub) that used the manufacturer's meats.  The manufacturer's meats became contaminated, triggering a recall.  The franchisees lost sales and goodwill as a result. 

The court found no duty owed to the franchisees.   It held that the losses sustained were not reasonably foreseeable by the manufacturer (para 84).

While the manufacturer was under a duty to supply meat fit for human consumption, and was taken to have represented that to the franchisees, the court held "the type of injury claimed – economic losses arising from reputational harm – did not fall within the scope of any duty owed to the franchisees" (para 68).

It may be interesting that the duty analysis does not refer to any of the cases about the supply of hazardous products or structures (the Winnipeg Condominium line of authorities). 

Stephen