Does a plaintiff have an obligation to take all reasonable measures to reduce her damages?

A plaintiff has an obligation to take all reasonable measures to reduce her damages, including undergoing treatment to alleviate or cure injuries: Danicek v. Alexander Holburn Beaudin & Lang, 2010 BCSC 1111, at para. 234.

The duty to mitigate is a positive duty but if a defendant’s position is that the plaintiff could reasonably have avoided some part of the loss, the defendant bears the onus of proof on that issue: Graham v. Rogers, 2001 BCCA 432, at para. 35.

A defendant who wishes to establish that a plaintiff has failed to mitigate her loss must prove two things: 1) that the plaintiff acted unreasonably in eschewing the recommended treatment; and 2) the extent, if any, to which the plaintiff’s damages would have been reduced had she acted reasonably: Chiu v. Chiu, 2002 BCCA 618 [Chiu], at para. 57.