We respectfully, but emphatically, dissent. The three million dollar question in this case is whether Metropolitan Edison waived its right to a new trial by failing to make a timely objection to a flawed jury instruction. The record unambiguously and incontrovertibly shows that this issue was waived. The majority reaches the opposite conclusion only by ignoring the record, and by misconstruing our Supreme Court’s well-known and oft-reaffirmed waiver rule in Dilliplaine. Because the majority’s discussion omits key parts of the development of how the trial court defined outrageousness in terms of negligence (which we will call the “outrageousness as negligence” issue), we will review it in its entirety.
I.
The fatal error in this case lurked within verdict interrogatory number nine, which dealt with punitive damages. It read:
Do you find that Metropolitan Edison acted in a grossly negligent, reckless, willful or wanton manner in causing injuries to Mr. Takes?
R. 44, verdict slip (emphasis added). As the majority correctly holds, neither negligence nor even gross negligence can support an award of punitive damages. Thus, this question misstated the law, and the parties were bound to bring this error to the attention of the trial court. Specifically, somebody needed to point out the offending language; only thus could the court be apprised of the mistake, and correct it before it became entrenched. Pa.R.A.P. 302, 42 Pa.C.S.A.1
*125The record contains only one specific objection on the subject of punitive damages. This objection did not mention the “outrageousness as negligence” issue, or even refer to verdict interrogatory number nine. Rather, it concerned the court’s refusal to frame its punitive damage instructions with a particular fact situation. In discussing the court’s charge to the jury, defense counsel argued:
Therefore, Judge, taking that position, since I think the only scenario that makes it is they should be chargfed] this way — and let me finish just this part — if you allow the jury to wander around in the fact combination with this blanket charge: do you find they acted in a negligent, willful and reckless manner is prejudicial to the defense in this instance — because it suggests that the court thinks any combination of the facts that they would choose could infer wanton and reckless negligence from those facts and that’s just not the case.
N.T. 2/26/92 at 657. After more discussion, defense counsel again asked, “What happens to my proposition that the application of [punitive damages] is limited to a fact situation?” Id. at 661. The trial court then decided to give a general punitive damages charge, and refused to frame it with a specific fact situation. The court noted defense counsel’s exception. Id. at 662-663. Defense counsel reiterated this objection when asked about how the verdict interrogatories should be ordered. Id. at 669-670, 670-671.
The majority’s interpretation of this exchange is both unclear and unconvincing. It concludes from the above exchange that “counsel verbalized an objection to a charge which would permit elucidation of negligence concepts in the punitive damage charge.” Majority op. supra at 108. This conclusion is wrong for two compelling reasons.
Any reading of this discussion shows that defense counsel’s objection was over the court’s refusal to define outrageousness in terms of a particular fact situation. Defense counsel never *126mentioned the verdict interrogatory, or its wording. In fact, defense counsel’s language clearly shows that he also used the word “negligence” in describing the reckless indifference standard for punitive damages; that is, counsel used the same erroneous terminology as the flawed verdict interrogatory.
Secondly, the trial court itself concluded that this exchange concerned its refusal- to define outrageousness in terms of a particular fact situation. Trial court opinion, 2/26/93 at 6; majority opinion at 142. This is the only specific determination that the trial court made about issue preservation. We agree with the majority that when the trial court offers its recollection of the record to make a determination about issue preservation, we should defer. Hence, we defer to the trial court here because, as the majority emphasizes, we have the trial court’s own conclusion as to what this exchange was about. Id. The majority, contrary to its own statement of waiver policy, does not. Thus, the error in verdict interrogatory number nine went unnoticed during the. charge conference.
During the court’s instruction on the general principles of punitive damages, the following exchanges took place:
[The Court, charging the jury]: ... The amount of punitive damages awarded must not be the result of passion or prejudice against Metropolitan Edison on the part of the jury. The sole purpose of punitive damages and the only purpose for which you may make such an award, if you were to make such an award and set an amount of punitive damages, is to punish Metropolitan Edison’s outrageous conduct, if you were to find it as such, and to deter Metropolitan Edison and others from commission of like acts.
Question number nine asks that very question: Do you find that Metropolitan Edison acted in a grossly negligent, reckless, willful or wanton manner in causing injuries to Mr. Takes, and if you do, what damages do you find?
*127Gentlemen, are there any suggested corrections to the punitive damages, additions or corrections to the punitive damages instruction?
AT SIDE BAR:
[Defense counsel]: Just to that page, your Honor?
THE COURT: Yes, just to that page.
[Plaintiffs’ counsel]: Your Honor, I would like you to request the court to charge the standard jury instruction on punitive damages, 1400.
THE COURT: I will do that.
[Defense counsel]: My only objection, your Honor, is I don’t think that you have defined exactly the extent that you’ve got to go to show reckless.
THE COURT: A person’s conduct is outrageous when he acts with a bad motive, or when he acts with a reckless indifference, and I’m about to charge that.
[Defense counsel]: Fine, Judge.
IN OPEN COURT:
[The Court, continuing to charge the jury]: ... A person’s conduct is outrageous, and included among that would be reckless, negligent, willful or wanton, when that person acts with a bad motive or when he acts with reckless indifference to the interests of others. That is the definition with which we approach the issue.
Id. at 832-834 (emphasis added). Counsel still raised no objection to the use of “grossly negligent” in verdict interrogatory number nine. Moreover, the court exacerbated the error when it defined outrageousness in terms of ordinary negligence. Again, no objections were raised.
After finishing the charge, the court again asked for any suggested additions or corrections to the charge. Defense counsel responded, “Your Honor, I restate the Defendant’s objection to the Court’s charging on reckless and intentional and punitive damages.” The jury then retired to deliberate, without any specific objection to the court’s use of the terms “negligent” or “grossly negligent” in its charge on punitive damages.
*128The jury later returned with its verdict for the Takes. The verdict was read in open court.
[Court clerk]:' Question number nine: Do you find that Metropolitan Edison acted in a grossly negligent, reckless, willful or wanton manner in causing injuries to Mr. Takes? [The jury foreperson]: Yes, we do.
[Court clerk]: Question ten: State the amount of punitive damages you award for Plaintiff against Defendant?
[Jury foreperson]: Three million dollars.
N.T. 2/26/92 at 848 (emphasis added). Again, no objections were raised, and the jury was dismissed. At this point, the error became irrevocably set. It is also at this point that waiver attached, because nobody had noticed or pointed out the “outrageousness as negligence” mistake.
If there could be any lingering doubt as to whether Metropolitan Edison missed this error, a look at Metropolitan Edison’s post-trial motions must erase that doubt. Metropolitan Edison’s motions for post-trial relief made no mention of the court’s error in using the terms “negligent” and “grossly negligent” in defining punitive damages. Indeed, the motions persisted in defining outrageousness in terms of negligence, just as counsel did at the charge conference. The only punitive damage issue Metropolitan Edison raised was the issue it had preserved for appeal: whether punitive damages should have been limited to a single factual scenario. Metropolitan Edison’s first motion for post-trial relief argued
[t]hat the Trial Court erroneously refused Defendant’s point for charge No. 26 which reads as follows:
26. It is only if you find that the Plaintiff was advised by Metropolitan Edison that the capacitor was de-energized when Defendant Metropolitan Edison knew that it was not that you can find willful and wanton negligence on the part of Defendant Metropolitan Edison.
R. 70, Metropolitan Edison’s Motion for Post-Trial Relief, ¶ 3 (emphasis added).2 The two amended motions for post-trial *129relief added some claims, but still made no mention of the alleged error in the court’s instruction. Id. The majority’s claim that the “outrageousness as negligence” issue was included in post-trial motions is simply wrong. Majority op. at 124.
Despite never having been brought up at trial or in post-trial motions, the “outrageousness as negligence” issue suddenly appeared as the lead argument in Metropolitan Edison’s brief in support of post-trial motions. It was also at precisely this point — between the filing and briefing of post-trial motions — that Metropolitan Edison hired additional counsel from the Pittsburgh firm of Reed Smith Shaw & McClay to augment its trial counsel team from the Bethlehem firm of LaBrum & Doak. R. 54, 69.
In its opinion on post-trial motions, the trial court first addressed the question of whether Metropolitan Edison specifically objected to the use of the terms negligent and grossly negligent in its charge on punitive damages. The court wrote that “[a] review of the record discloses that Met Ed did preserve certain objections on the punitive damages issue.” Trial court opinion 2/26/93 at 3 (emphasis added). The court then reviewed the record of the jury charge conference and the charge itself, as laid out above. The court concluded:
Thus it is clear that Met Ed’s primary objection expressed at trial and intended to be preserved revolved around Met Ed’s contention that punitive damages would not lie absent a finding by the jury that Met Ed’s agent knowingly told the plaintiff that the capacitor was deenergized when he knew that it was not. The court rejected that contention. (N.T. February 26, 1992, pp. 661-662).
Having determined that Met Ed preserved its objections to the jury charge on punitive damages, as well as to the *130jury interrogatory concerning punitive damages, we now address the substantive issues raised by Met Ed.
Trial court opinion 2/26/93 at 6; majority op. at 109-110.
These two paragraphs of the trial court opinion are crucial, because they constitute the court’s entire discussion of issue preservation. The trial court recalled that the discussion and objection at the charge conference concerned Metropolitan Edison’s request for a fact-specific framing of punitive damages. That is the only record objection the trial court pointed to, and the only instance of preservation it discussed. The trial court did not cite any place in the record where Metropolitan Edison specifically objected to the court’s defining outrageousness in terms of negligence.3 The trial court did not even state that it recalled that the issue was raised and preserved off the record. The trial court offered no reason for its decision to ignore the Takes’ compelling waiver arguments. Rather, the trial court simply proceeded to review its use of the terms negligent and grossly negligent in defining punitive damages. The court concluded that the charge and verdict interrogatories as a whole were consistent with the law, and were therefore proper. Trial court opinion at 14.
We emphasize again that we agree with the majority’s statement that appellate courts should defer to a trial court’s specific recollections concerning issue preservation. That is one reason why the objection during the charge conference does not preserve the “outrageousness as negligence” issue— because the trial court has specifically told us that this objection went to a different issue. Unlike the majority, we actually do defer to the trial court’s specific recollection of the trial proceedings.
The problem here is that the trial court has not given us anything to defer to on the “outrageousness as negligence” issue. It simply addressed it without discussing preservation at all, even though the post-trial briefs disputed whether the *131issue had been preserved. The trial court gave no reason for its implicit conclusion that the issue was preserved — no citation to the record, no discussion, not even an assurance that it recalled that the issue was raised, despite its conspicuous absence from the record.
Hence, the record compels us to conclude that the issue was missed. The waiver is palpable, not just from the utter absence of objection at trial, but also because of its conspicuous absence from post-trial motions. Waiver shines forth from the record like a beacon. Under such circumstances, the trial court must give us some reason not to find waiver. We might accept a trial court’s assurance that despite the absence of record objection, it recalled the issue as being preserved. But here, the trial court has not done even this. We cannot defer when the trial court gives us nothing to defer to.
The majority, however, chooses to interpret the trial court’s silence as a finding of issue preservation. It then chooses to defer to that implicit finding, treats the issue as preserved, and holds that the flawed verdict interrogatory requires a new trial. In so holding, the majority not only does violence to the record, it does even greater violence to our law of waiver as announced in Dilliplaine v. Lehigh Valley Trust Co., 457 Pa. 255, 322 A.2d 114 (1974).
II.
Dilliplaine requires trial counsel to make timely, specific objections during trial, to
ensure that the trial judge has a chance to correct alleged trial errors. This opportunity to correct alleged errors at trial advances the orderly and efficient use of our judicial resources.
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Appellate court consideration of issues not raised in the trial courts results in the trial becoming merely a dress rehearsal. This process removes the professional necessity for trial counsel to be prepared to litigate the case fully at trial and to create a record adequate for appellate review.
*132The ill-prepared advocate’s hope is that an appellate court will come to his aid after the fact and afford him relief despite his failure to object to an alleged error. The diligent and prepared trial lawyer — and his client — are penalized when an entire case is retried because an appellate court reverses on the basis of an error opposing counsel failed to call to the trial court’s attention. Failure to interpose a timely objection at trial denies the trial court the chance to hear argument on the issue and an opportunity to correct its error.
Id. at 257, 322 A.2d at 116.
This is the heart of our waiver doctrine. Our high court has emphasized its importance countless times, most recently in McMillen v. 8k Lumber, Inc., 538 Pa. 567, 649 A.2d 932 (1994). It is not a technical procedural rule which may be overlooked by the trial court, like a rule 227.1(b)(2) violation.4 Rather, it is substantive law, embodying a strong statement of policy. Both this , court and the trial court are bound to apply it without regard to the result. See McMillen, supra.
*133The trial court did not apply Dilliplaine, however. The question of preservation was joined — the Takes brief on post-trial motions strenuously argued that Metropolitan Edison had not preserved the “outrageousness as negligence” issue. As we have set forth at great length, the Takeses were correct. But the trial court ignored the waiver arguments before it, and addressed the issue anyway; it gave no reason for doing so. The question of first impression here is whether we are absolutely bound by the trial court’s decision.5 That is, can an appellate court make any determinations from the record concerning issue preservation, or must we accept every implicit trial court determination on issue preservation — even patently erroneous determinations which violate the law of waiver as set forth in Dilliplaine?
We cannot agree with the majority’s affirmative answer. We do agree that we should give the trial court the greatest deference here, since it knows best what actually transpired at trial, and how well the record reflects these events. But this deference cannot be blind. The whole purpose of making a record at trial is so appellate courts can review it. Every trial attorney in this Commonwealth knows how vitally important it is to state timely, specific objections on the record in order to preserve them for appeal. Should a trial court be able to obviate the entire purpose of making a record and nullify the mandates of Dilliplaine just by addressing an issue? We do not think so. The policy behind deference is strong, but so is the rationale of Dilliplaine. Only in the rarest of cases will the waiver be so clear, the trial court’s decision to ignore waiver be so unsupportable, and the consequences of ignoring *134waiver be so weighty that an appellate court would be justified rejecting the trial court’s decision on preservation. This, however, is precisely such a case.
We have outlined the waiver here at great length: despite the many opportunities, nobody mentioned the problem with verdict interrogatory number nine — not during trial, not after trial, not until after post-trial motions were filed, when Metropolitan Edison had hired new counsel. We have also discussed the trial court’s failure to address the question of preservation: the court did not cite the record, discuss preservation, or even state that it recalled that the issue was raised, despite its obvious absence from the record. What remains is to consider the consequences of the majority’s blind deference to the trial court’s unsupported and unsupportable decision.
III.
The consequence of the majority’s holding is a new trial. Dilliplaine’s purpose is to avoid the cost of new trials, both to the judicial system and to the parties. As the large record attests, this was a major and no doubt expensive trial. Post-trial and appellate proceedings have already taken more than three years so far, adding that much more expense, delay, and frustration. Now the majority orders a new trial. The costs to the judicial system are considerable; the costs to Stephen and Catherine Takes are far greater.
In an attempt to mitigate this burden, the majority has limited the new trial to the issue of punitive damages. Such a trial makes no sense, and is contrary to Pennsylvania law. Our research has revealed not a single case in this Commonwealth where a new trial was ordered on punitive damages alone. A new trial may be limited to damages, but only where the matter of damages is not intertwined with liability. Lininger v. Kromer, 238 Pa.Super. 259, 273, 358 A.2d 89, 96 (1976). To award punitive damages, a jury must determine the culpable quality of a defendant’s conduct — that is, whether it acted outrageously. This requires a full trial on the facts. A jury could not be told that Metropolitan Edison is 100% *135liable for Mr. Takes’ injuries and still make unbiased factual determinations. As the majority concedes, liability is inexorably intertwined with punitive damages: a jury must determine what the culpable conduct is before it can decide if that conduct is outrageous. To be meaningful, a new trial would have to be a full trial, with all the attendant costs to the parties and court system. Dilliplaine is still subverted.
Still, the trial court might theoretically be able to conduct a full trial on remand, throw out any compensatory verdict, and keep only the possible punitive damage award. Even under this costly and burdensome procedure, it seems highly unlikely that a jury would award punitive damages this second time. At the first trial, the jury saw Metropolitan Edison try to justify, rationalize and blame Mr. Takes for the utility’s clearly outrageous conduct. At a second trial, Metropolitan Edison could put on a very different face: it would apologize for this tragic mistake and open itself to as large a compensatory verdict as the jury cared to give, since the second jury’s compensatory verdict would be a nullity. A strategy of contrition could effectively avoid a punitive damage award.
It is important to bear in mind that the purpose of punitive damages is to deter future outrageous conduct. When a jury sees a defendant try to justify its blatantly reckless conduct in court, it may rightly conclude that this defendant will continue its outrageous ways unless punished. Cf. Boggavarapu v. Ponist, 518 Pa. 162, 166-168, 542 A.2d 516, 518 (1988) (a jury may properly consider the way a case is presented in determining damages). A review of the trial testimony shows that Metropolitan Edison knowingly allowed Mr. Takes to paint a live, five kilovolt capacitor. This conduct is a paradigm of reckless indifference; public policy strongly calls for a punitive damage award to deter such conduct.6 The majority’s *136novel approach to a “limited” new trial thus both contravenes Pennsylvania law and effectively scuttles the policy behind punitive damages. It acts as a de facto remittitur, and a particularly unconscionable one.
IY.
Thus we have a case which fully implicates the policy behind Dilliplaine, and brings to the fore the inherent tension between waiver doctrine and the majority’s policy of blind deference to the trial court’s preservation determinations. As the majority notes, this case is not the first time that we have been presented with a situation where an issue was waived, but we have deferred to the trial court decision to address it anyway. See James v. Nolan, 418 Pa.Super. 425, 428, 614 A.2d 709, 711 n. 1 and n. 2 (1992); Smith v. Brooks, 394 Pa.Super. 327, 340, 575 A.2d 926, 932 n. 2 (1990), alloc. denied, 527 Pa. 621, 592 A.2d 42 (1991).7 In those cases, however, our deference came at no cost to the parties because .we affirmed the trial court, and no new trials were needed. See fn. 5, supra.
Neither the Nolan nor Brooks courts announced any authority for their decisions to address issues that they were convinced had been waived at trial. While this policy of deference is rooted in sound principles of appellate practice, it is still an ad hoc policy. Dilliplaine, on the other hand, is controlling law.
Moreover, the question before us is not how we would balance our ad hoc deference policy against waiver policy; the question is how our Supreme Court would balance' these two *137competing policies. As our high court has recently reminded us, it believes in the rationale of Dilliplaine, and will not countenance departures without compelling reasons. McMillen v. 84 Lumber, Inc., 538 Pa. 567, 571, 649 A.2d 932, 934 (1994) (reversing Superior Court’s overbroad application of public interest exception to waiver rule). Given our Supreme Court’s repeated and forceful statements that it takes waiver seriously, we do not believe that it would follow the majority’s course and allow Dilliplaine to be side-stepped by a trial court’s oversight or mistake.
For indeed, that is the import of the majority’s approach: it essentially holds that a trial court determination that an issue has been preserved can never be mistaken. The mere fact that a trial court treats an issue as preserved means that it has been preserved, and an appellate court is powerless to find otherwise. While we may accord a trial court great deference in many areas, confining our review to gross or palpable abuses of discretion, we can think of no other area where a trial court’s finding would be utterly immune from review. As McMillen illustrates, lower courts may not always appreciate the sweep of a doctrine like waiver, or perhaps they may not fully understand how to implement it. Mistakes are possible. When they happen, we should acknowledge and correct them, not entrench and exacerbate them with an ad hoc policy of unconditional deference.
Two examples illustrate the danger of unconditional deference to trial court preservation determinations. Suppose the present situation were reversed: the trial court held in its opinion that an issue had been waived, even though counsel made timely, specific objections on the record. There can be little question that we would treat a properly preserved issue as preserved, despite the trial court’s contrary opinion on preservation. See Graham v. Sky Haven Coal, Inc., 386 Pa.Super. 598, 612, 563 A.2d 891, 898 n. 1 (1989) (en banc) (Brosky, J. concurring and dissenting). To do otherwise would be contrary to the law of waiver, and would unfairly punish a litigant for a trial court’s mistake.
*138Likewise, unwarranted deference in the present posture also contravenes our waiver law, gives a windfall to the unprepared party and unfairly burdens the non-negligent party, all in contravention of Dilliplaine. In James v. Nolan, supra, our deference to the trial court’s preservation determination was clearly unwarranted. The appellant in Nolan argued that the jury rendered an inconsistent verdict, but appellant failed to object to the verdict before the jury was dismissed. The trial court addressed the post-trial motion for a new trial because of verdict inconsistency, even though counsel might have solved any problem by pointing out the alleged inconsistency to the court while the jury was still impaneled. We felt that counsel’s failure to object before the jury was dismissed constituted waiver, but we deferred to the trial court and addressed the issue on its merits. Nolan, supra 418 Pa.Super. at 428, 614 A.2d at 711, n. 1 and n. 2.
It is absolutely clear, however, that such delay does constitute waiver. Philadelphia Police Dept. v. Gray, 534 Pa. 467, 633 A.2d 1090 (1993); Curran v. Greate Bay Hotel and Casino, 434 Pa.Super. 368, 643 A.2d 687 (1994) (en banc); Picca v. Kriner, 435 Pa.Super. 297, 645 A.2d 868 (1994); Krock v. Chroust, 330 Pa.Super. 108, 478 A.2d 1376 (1984). We were correct that the issue had been waived, and the trial court was wrong — we should not have deferred. But because we affirmed the trial court on the merits, our mistake in deferring to the trial court’s preservation decision became moot. If our review in Nolan would have resulted in reversing the trial court and ordering a new trial, it would have been in direct contravention of Dilliplaine. That is precisely what is happening in this case.
The only context where our high court has indicated that we might relax our application of waiver is in criminal cases. Since criminal defendants have a constitutional right to effective assistance of counsel, trial counsel’s failure to preserve meritorious issues for appeal does not act as a permanent waiver; defendants may have a right to revisit waived issues with new counsel on appeal, or through the Post Conviction Relief Act. Thus in criminal cases, we may choose to ignore *139possibly waived issues for purposes of judicial economy, in order to pre-empt future litigation. See Commonwealth v. Sees, 529 Pa. 450, 451, 605 A.2d 307, 308 n. 1 (1992). Civil litigants, however, have no right to effective assistance of counsel. We do not conduct new civil trials so that counsel can do a better job, but to correct errors which may have infected the verdict. Dilliplaine requires that we not give counsel a second bite at the apple unless counsel has preserved that error.
V.
In sum, we have a case where the jury rendered a verdict based on a flawed interrogatory and instructions. The record shows that nobody noticed the mistake. We cannot emphasize enough how clear the waiver is: the mistake did not come to light until after post-trial motions were filed. Yet, the trial court addressed the issue. We do not know why. The trial court did not say why it was addressing this issue which so plainly had been waived. It gave no reason at all for ignoring the compelling waiver argument before it. The majority accepts this incorrect and unfathomable decision as binding, addresses the issue on the merits, and is compelled to order a costly and impractical new trial.
We feel certain that given its strong policy on waiver, our Supreme Court would not countenance this result. Waiver is about more than just discouraging gamesmanship. Cf. majority op. at 143. The central purpose of waiver is to motivate counsel to catch and fix errors at the trial level, so they do not become issues for appeal and necessitate new trials. Dilliplaine, supra 457 Pa. at 257-259, 322 A.2d at 116. Of course, counsel can only catch errors; it is up to the trial court to fix them. That is why we require counsel to preserve issues on the record. Just as trial courts can make mistakes which require new trials, so might a trial court make a mistake regarding issue preservation. To immunize this type of potential error from review completely frustrates waiver policy.
*140Hence, we think that an appellate court must exercise some limited review of a trial court’s determination on whether an issue has been properly preserved. This should be the narrowest, most deferential review possible. We should accept the trial court’s interpretation of the record, since it knows best what transpired at trial. We might even allow for the remote possibility that an objection might not appear on the record; if the trial court assures us that an issue was raised off the record, we may accept its determination.
But we must acknowledge that judges are not infallible. When a judge mistakenly treats an issue as having been preserved, we cannot be bound by that erroneous determination. To employ such a policy of blind deference “would substantially eviscerate the waiver principle.” McMillen, supra at 571, 649 A.2d at 934. That is just what the majority does here, and accordingly we must dissent.
CIRILLO and POPOVICH, JJ., join.. Rule 302(b) reads:
*125Charge to Jury. A general exception to the charge to the jury will not preserve an issue for appeal. Specific exception shall be taken to the language or the omission complained of.
. We note that the failure to include the issue in post-trial motions is also grounds for waiver under Pa.RX.P. 227.1(b)(2). While the trial *129court may overlook noncompliance with rule 227.1(b)(2) and choose to address an issue even though it was absent from post-trial motions, the issue must still have been preserved pursuant to Dilliplaine: that is, “it must be raised timely in pre-trial proceedings or during the trial, thus affording the court an opportunity to correct the error.” Explanatory comment to rule 227.1(b)(1).
. Of course, neither has Metropolitan Edison. We have taken care to lay out this issue in full, and in proper chronology, to show that the very first time the issue was mentioned was in Metropolitan Edison’s brief supporting its post-trial motions.
. We emphasize that this case presents an issue of substantive, not procedural, waiver. If Metropolitan Edison had only failed to include the "outrageousness as negligence” issue in its post-trial motions, then the trial court could choose to overlook that defect, and we would be bound to do likewise. American Association of Meat Processors v. Casualty Reciprocal Exchange, 527 Pa. 59, 67, 588 A.2d 491, 495 (1991) (the purpose of rule 227.1 is to effect the waiver doctrine of Dilliplaine: to bring errors to the attention of the trial court so they can be corrected, rather than raising them for the first time on appeal; when the trial court is given sufficient opportunity to correct its own error, Dilliplaine is satisfied and further application of waiver for post-trial procedural error would be superfluous); see also Kurtas v. Kurtas, 521 Pa. 105, 555 A.2d 804 (1989) (Pa.R.C.P. 126 permits courts to overlook procedural defects in order to advance justice and fairness; thus, when a trial court chooses to ignore any technical non-compliance with rule 227.1, appellate courts should do likewise).
Here, counsel had every opportunity to bring the error to the court’s attention and correct it during trial, but failed. When the jury was dismissed, the error became set. It was at this point that waiver attached — not at post-trial motions. The waiver here does not stem from a violation of a procedural rule, which the trial court is empowered to overlook under rule 126. Rather, it stems from the violation of the substantive law of Dilliplaine, which both the trial court and this Court must follow.
. This Court has on occasion chosen to address issues on the merits because the trial court has elected to do so, despite our conviction that the issues were waived at trial. James v. Nolan, 418 Pa.Super. 425, 428, 614 A.2d 709, 711 n. 1 and n. 2 (1992); Smith v. Brooks, 394 Pa.Super. 327, 340, 575 A.2d 926, 932 n. 2 (1990), alloc. denied, 527 Pa. 621, 592 A.2d 42 (1991). In those cases, our deference did not implicate the policy behind Dilliplaine because we affirmed the trial courts’ rulings. Whether we held the issues waived or addressed them on the merits, no new trials were required. Here, the consequence of deference is a new trial. Hence, for the first time we are presented with a true conflict between our ad hoc policy of deference on issue preservation and the mandates of Dilliplaine.
. See Feld v. Merriam, 506 Pa. 383, 485 A.2d 742 (1984) (adopting Restatement (Second) of Torts, § 908(2)); SHV Coal v. Continental Grain Co., 526 Pa. 489, 494, 587 A.2d 702, 704 (1991) (when an "actor knows ... of facts which create a high degree of risk of physical harm to another, and deliberately proceeds to act, or to fail to act, in conscious disregard of, or indifference to that risk,” this demonstrates a particularly high degree of culpability, which can justify a punitive *136damage award) (citing Restatement (Second) of Torts § 500, comment a).
Despite these strong facts, we must agree with the majority’s conclusion that this error cannot be regarded as harmless. Majority op. at 148-149. To do so would plainly invade the jury’s fact-finding province.
. In both Nolan and Brooks, our deference to the trial court's preservation decision was not a major issue; we used footnotes to note our disagreement with the trial court’s preservation determination and to defer nonetheless. Here, preservation is the central issue on appeal.