Breighley Touring Ltd is a small travel and tours company owned by Terry Breigh and Tobin Equipment Ltd. Terry Breigh is the only officer of Breighley and he is the sole shareholder of Tobin Equipment Ltd. Breigh used a Ford Escape vehicle purchased by and registered to Breighley for the personal use of his family. The use of the vehicle by the corporation and family members was properly reflected in the corporation's financial statements and tax returns. The vehicle was also driven by Breighley's employees.

While Breigh's son Tim was driving the Escape, he was involved in a collision with another vehicle. At the time of the accident, Tim had his father's permission to drive the vehicle even though he had a poor driving record and had only recently had his driver's licence reinstated. The driver of the other vehicle, Marilyn Meadows, sustained serious injuries. She brought an action against Breighley as registered owner of the vehicle, Tim as driver of the vehicle, and Terry Breigh.^{83}83 On what basis could Terry be potentially liable for Marilyn's injuries? What argument(s) could be presented on behalf of Marilyn? What argument(s) could Terry use to avoid liability?