Is it necessary for a plaintiff to advance a future cost of care claim, in a medical malpractice action, to have a physician testify to the medical necessity of each and every item of care?

British Columbia, Canada


The following excerpt is from Clost v. Relkie, 2012 BCSC 1393 (CanLII):

In Gregory v. Insurance Corporation of British Columbia, 2011 BCCA 144 at para. 39, Garson, J.A. stated: I do not consider it necessary, in order for a plaintiff to successfully advance a future cost of care claim, that a physician testify to the medical necessity of each and every item of care that is claimed. But there must be some evidentiary link drawn between the physician’s assessment of pain, disability, and recommended treatment and the care recommended by a qualified health care professional: Aberdeen at paras. 43, 63.

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