In Rosvold v. Dunlop, 2001 BCCA 1, Madam Justice Huddart stated that compensation under this heading is not for a loss of projected earnings (a mathematical approach), but rather for the impairment of earning capacity as a capital asset. She commented that past earnings may be a useful fact to consider, but they are not the only fact that should be considered. She summarized the case law as follows:
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