This is one of the limited examples offered by the plaintiff as to the pecuniary loss that might be embraced by a claim for loss of love, care, guidance, and companionship. Notably, such loss was not treated as a separate head of damage in Brown v. Finch, but rather as a positive contingency that ought to have been accounted for in the overall pecuniary award. Brown v. Finch provides no support for the existence of a head of damage under the Family Compensation Act for loss of love, care, guidance, and companionship.
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