Does a loss of housekeeping services provided by a member of the same family preclude an award for loss of Housekeeping capacity?
British Columbia, Canada
The following excerpt is from Jarrett v Wold, 2021 BCSC 302 (CanLII):
It is also well established that gratuitous housekeeping services provided by family members will not preclude an award for the loss of housekeeping capacity: Dykeman v. Porohowski, 2010 BCCA 36 at para. 28.
Because an award under this head of damages compensates a plaintiff for diminished ability, a claim for loss of housekeeping capacity can be awarded even if a plaintiff is awarded future care damages to replace homemaking services: Schenker v. Scott, 2014 BCCA 203 at paras. 93, 94 [Schenker].
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