Is loss of housekeeping capacity compensated as part of assessment of non-pecuniary damages?

British Columbia, Canada


The following excerpt is from Schaffner v Greenbank, 2021 BCSC 1603 (CanLII):

Loss of housekeeping capacity may be compensated by a pecuniary award, or it may be considered as part of the assessment of non-pecuniary damages: McTavish v. MacGillivray et al., 2000 BCCA 164 at para. 73.

Where a plaintiff suffers an injury that would make a reasonable person in the plaintiff’s circumstances unable to perform usual and necessary household work, a pecuniary damages award may be appropriate. Where the loss is more in keeping with a loss of amenities, or increased pain and suffering, the loss may be more appropriately addressed as part of a non-pecuniary damages award: Quigley v. Cymbalisty, 2021 BCCA 33 at para 72.

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