What is the test for exemplary damages in a motor vehicle accident case?

The basis on which such damages may be awarded was described by Lord Devlin in Rookes v. Barnard, [1964] A.C. 1129, [1964] 1 All E.R. 367, at p. 1228 [A.C.]: In a case in which exemplary damages are appropriate, a jury should be directed that if, but only if, the sum which they have in mind to award as compensation (which may, of course, be a sum aggravated by the way in which the defendant has behaved to the plaintiff) is inadequate to punish him for his outrageous conduct, to mark their disapproval of such conduct and to deter him from repeating it, then it can award some larger sum.