What is the legal test for refusing to award an award of interest in a personal injury case?

Judicial discretion has also been exercised to refuse an award of interest. In Evergreen Irrigation v. Belgium Farms Ltd. (1976) 3 A.R. 248, Brennan, J. was unwilling to allow interest on the ground that: “There certainly were issues involved in this matter which the defendant was entitled to have tried and considered by the court and for that reason I do not find that it just arbitrarily upheld the payment, of the balance owing to the plaintiff and accordingly interest will hot, therefore, be allowed.”