Appellate review of civil jury instructions will focus on the charge as a whole. Even if one statement within a charge amounts to a misdirection, “it is the charge as a whole that must be considered to determine whether the misdirection may have misled the jury or whether the issues were placed before it fairly”: Alden v. Spooner, 2002 BCCA 592 at para. 20, leave to appeal ref’d, [2002] S.C.C.A. No. 535.
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