34 There is, in the area of liability of parents for injury caused to children, a reluctance of the courts to impose a duty on the parents: see Robertson v Swincer (1989) 52 SASR 356; Posthuma (supra); Towart v Adler (1989) 52 SASR 373; but see McCallion v Dodd [1966] NZLR 710. It is rather surprising that a driver can be held liable in negligence for failing to notice a child running out onto the road, but the parents who were present and who failed to stop the child going out onto the road (Swincer) are not liable, or that parents who, in opening a window failed to appreciate the danger in a bunk set up for which the landlord was held liable (Towart), should be excused from liability on the basis of 'policy'. There may be a concern at the prospect of a myriad of claims by children against their parents, but, accepting the legitimacy of that concern, it seems, with respect, a different situation when a third party is sued for injury to the child. There may well be a perception that those third parties who have injured the child are likely to be insured (drivers would certainly fall into that category) and the parents not insured, but the third party is not necessarily insured, and the existence of insurance ought not determine liability: see McCallion v Dodd at p721 ll 27-31. The comments of Turner J at p727 of McCallion raise an interesting possible solution to the difficulty - the revival of 'identification', an approach which his Honour noted had not been run on the appeal, and which had fallen into desuetude. The fact that liability is imposed on a school because it is in a position to exercise authority over a child (see Ramsay v Larsen (1964) 111 CLR 16; Richards v State of Victoria [1969] VR 136, 138-9; and Commonwealth v Introvigne (1982) 150 CLR 258 only emphasises the incongruity of rejecting parental liability where liability is to be imposed on a third party, in my view, and see also Fleming "The Law of Torts" (9th edn) at p 748). For a discussion of policy issues touching on the matter see S Yeo, "Am I my Child's Keeper? Personal Liability in Negligence" (1998) 12 AJFL 150.