What is the test for recovery of damages for wrongful conception?

If neither the application of strict tort principles (with or without the offset for benefits) nor public policy illuminates the principles on which child-rearing costs are recoverable, some other basis must be found. In an article which considered the Ontario case Doiron v. Orr, J.E. Bickenbach, “Damages for Wrongful Conception: Doiron v. Orr” (1979-80), 17 U.W.O.L. Rev. 493, the author suggests that the birth of a child is not properly analyzed as a benefit but that the legal significance of a child’s birth is that it creates responsibilities. There is support for this view in law, in public policy, and as a matter of common sense.