What is the test for future costs of child care?

British Columbia, Canada


The following excerpt is from Carmichael v. Kwon, 2016 BCSC 265 (CanLII):

I observe that in subsequent decisions of this court, the future costs of child care have been allowed. For example, in Gillam v. Wiebe, 2013 BCSC 565, Mr. Justice Verhoeven allowed a claim for the child care costs for the plaintiff on the basis that it replaced a care giving capacity that the plaintiff otherwise had:

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