What is the test for recovery for loss of income capacity?

British Columbia, Canada


The following excerpt is from Lewis v. Scheer, 2014 BCSC 573 (CanLII):

In Perren v. Lalari, 2010 BCCA 140, our Court of Appeal set forth, at para. 32, the rule that there must be a “real and substantial possibility of a future event leading to an income loss” for there to be recovery for loss of income capacity. The loss may be quantified using the earnings approach or the capital asset approach.

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