Is there a duty of good faith and respect to a dedicated wife or mother who chooses to devote her life to looking after an elderly husband and son?

Alberta, Canada


The following excerpt is from Bain v. Calgary Board of Education, 1993 CanLII 7301 (AB QB):

Dickson J. in Andrews v. Grand & Toy Alberta Ltd., 1978 CanLII 1 (SCC), [1978] 2 S.C.R. 229 at 243, [1978] 1 W.W.R. 577, 3 C.C.L.T. 225, 83 D.L.R. (3d) 452, 8 A.R. 182, 19 N.R. 50, stated: … there is now ample authority for saying that dedicated wives or mothers who choose to devote their lives to looking after infirm husbands or sons are not expected to do so on a gratuitous basis. Dickson J. further stated at p. 242: … there is no duty to mitigate, in the sense of being forced to accept less than real loss. There is a duty to be reasonable. There cannot be "complete" or "perfect" compensation. An award must be moderate and fair to both parties.

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