Chronic pain satisfies the requirements of permanence for the purposes of the threshold. As stated in paragraph 87 of Hartwick v. Simser, [2004] O.J. No. 4315, 87 It is now trite law that chronic pain arising from injury sustained in a motor vehicle accident, and which accounts for limitation in function unlikely to improve for the indefinite future, will meet the requirement of "permanence" in the threshold.
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