Athey v. Leonati is the leading case in Canada on the subject of subsequent events which aggravate injuries received in a tortiously caused accident. The case recognizes that there may be more than one material cause of injuries and holds that if injuries caused by a tortfeasor are found to be a material contributing cause of the exacerbation of those injuries by a subsequent event, then the original tortfeasor may be liable for not only the initial injuries, but also for their subsequent exacerbation.
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