In Brennan v. Cockrell Investments, Inc. (1973) 35 Cal. App. 3d 796, the court stated that questions of possession and control, formerly a "prerequisite to even a consideration of the negligence of an owner or occupier of land," in the aftermath of Rowland v. Christian are still relevant "as they bear on such basic tort issues as the foreseeability and unreasonableness of the particular risk of harm." (Id. at p. 801.) As the court explained: "Possession and degree of control over the premises are significant factors to be weighed in determining whether or not the landlord failed to meet the statutory standard of care" and "go to the very essence of the negligence issue." (Id. at p. 800.)