When will insurance coverage be considered in a personal injury action?

In Hunter v. Anderson, 2010 BCSC 1591 at para. 22, Cullen J. (as he then was) held that insurance coverage may be considered where it “creates an unfair advantage leading to unnecessary costs through testing the plaintiff's case”, citing Smith and Radke for support. While consideration of insurance coverage would certainly be justified where an insured party exploits a financial disparity to test the other party’s case unnecessarily, I do not think that such circumstances must always be present. As Humphries J. stated in Mazur, at paras. 50-53, Smith stands for the general principle that insurance coverage is a valid consideration for the factor of relative financial circumstances, and it does not limit the application of that principle to its specific facts. The issue of whether insurance coverage merits consideration will turn on the circumstances of each individual case.