Virginia Code § 8.01-65

Defense of lack of consent of owner
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It shall be a valid defense to any action brought for the negligent operation of a motor vehicle for the owner of such vehicle to prove that the same was being driven or used without his knowledge or consent, express or implied, but the burden of proof thereof shall be on such owner.
Code 1950, § 8-646.8; 1977, c. 617.

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