What is the test for determining past wage loss?

British Columbia, Canada


The following excerpt is from Naidu v Dhami, 2021 BCSC 668 (CanLII):

Compensation for past wage loss is based on what a plaintiff would have earned if not for the accident. The burden of proof of actual past events is a balance of probabilities. Hypothetical events, on the other hand, need only be real and substantial possibilities and then allowances are made for contingencies. The loss may be quantified on an earnings or capital asset approach, and the assessment must be fair and reasonable between the parties. (Grewal v. Naumann, 2017 BCCA 158, at paras. 70-71).

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