Such a word is often used loosely. I expect in this case the meaning would be the first one. For instance if someone walked into a tree in the dark and injured themself they might claim the owner of the tree is liable for their injury by placing an obstacle in the highway and not clearly lighting it so it could be seen.
yes. perhaps it wasn't the best choice of words...
here in the US, if someone was walking while texting and ran into one of those unlit trees & bruised his/her ego, a lawsuit against the property owner is a real possibility.
What! you would put the lights down low to make it even easier for young morons to smash them?
most municipal grade fixtures are vandal resistant. recessed & camouflaged fixtures helps curb vandalism. out of sight, out of mind type of thing...
heres some nice examples of what i was trying to describe.
source. much nicer looking imo.
-sj