What are the principles applicable to the assessment of damages for loss of earning capacity?

The principles applicable to the assessment of damages for loss of earning capacity were expressed in Perren v. Lalari, 2010 BCCA 140 at para. 22: A plaintiff must always prove … that there is a real and substantial possibility of a future event leading to an income loss. If the plaintiff discharges that burden of proof, then depending upon the facts of the case, the plaintiff may prove the quantification of that loss of earning capacity, either on an earnings approach … or a capital asset approach … The former approach will be more useful when the loss is more easily measurable …. The latter approach will be more useful when the loss is not as easily measurable … A plaintiff may indeed be able to prove that there is a substantial possibility of a future loss of income despite having returned to his or her usual employment. …. But … an inability to perform an occupation that is not a realistic alternative occupation is not proof of a future loss. [Citations omitted.]