In Bushnell v. Japanese-American Religious & Cultural Center (1996) 43 Cal.App.4th 525, Division One of this district went a step further in discussing Tan and Galardi in the context of a case in which a student was injured while practicing throws with an instructor at a judo club. The Court of Appeal affirmed summary judgment entered in favor of the defendant club. ( Bushnell, supra, 43 Cal.App.4th at pp. 528-529.) The court noted "in all cases in which the doctrine of primary assumption of risk is asserted as a bar to recovery the nature of the activity, the relationship of the defendant to the activity and the relationship of the defendant to the plaintiff must be examined. It must then be determined, in light of the activity and these relationships, whether the defendant's conduct at issue is an 'inherent risk' of the activity such that liability does not attach as a matter of law. General rules of liability attach when the defendant's conduct is not an inherent risk of the activity or when the defendant's conduct increased the inherent risks in the activity." ( Id. at p. 530.) The court went on to state that the "doctrine of primary assumption of risk can apply even if the defendant was in some manner in control of the situation and thus in a better position than the plaintiff to prevent the plaintiff's injury." ( Bushnell, 43 Cal.App.4th at p. 531.) In support of that proposition, the Court of Appeal cited Ford v. Gouin (1992) 3 Cal.4th 339, 11 Cal. Rptr. 2d 30, 834 P.2d 724, the companion case to Knight, in which the Supreme Court applied the doctrine to find that a ski boat driver did not have a duty to avoid an overhanging branch and consequent injury to someone skiing backwards and barefoot behind his boat. ( Bushnell, supra, 43 Cal.App.4th at p. 531.) The court then revisited Tan and Galardi and indicated that it believed that both were consistent with Knight and Ford, if they were read as finding liability on the defendants' part based on their having "increased the inherent risks" of the activity in question. ( Id. at p. 534.) However, the Bushnell court disagreed with Tan and Galardi to the extent that they might be read as establishing a broad rule that instructors owe a general duty of care to their students, finding such a rule inconsistent with both the language set forth in, and the policies underlying, Knight and Ford. ( Bushnell, supra, 43 Cal.App.4th at pp. 533-534.)