Quoting%20commentary for Bava Kamma 6:1

הַכּוֹנֵס צֹאן לַדִּיר, וְנָעַל בְּפָנֶיהָ כָּרָאוּי, וְיָצְאָה וְהִזִּיקָה, פָּטוּר. לֹא נָעַל בְּפָנֶיהָ כָּרָאוּי, וְיָצְאָה וְהִזִּיקָה, חַיָּב. נִפְרְצָה בַלַּיְלָה אוֹ שֶׁפְּרָצוּהָ לִסְטִים, וְיָצְאָה וְהִזִּיקָה, פָּטוּר. הוֹצִיאוּהָ לִסְטִים, לִסְטִים חַיָּבִים:

If one brings a sheep into a shed and closes (the door) before it properly, and it goes out and causes damage, he is not liable. [For he guarded it. "What (else) could he have done?"] If he does not close before it properly, and it goes out and causes damage, he is liable. If it were breached at night, or if robbers breached it and it went out and caused damage, he is not liable. If robbers took it out, the robbers are liable. [Even if they did not actually take it out, but just stood before it until it went out, it is as if they took it out with their hands and they are liable.]

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