What is the test for punitive damages in a case brought by a plaintiff against the Church of Scientology?

In Hill v. Church of Scientology, 1995 CanLII 59 (SCC), [1995] 2 S.C.R. 1130 at 1208, 126 D.L.R. (4th) 129, 25 C.C.L.T. (2d) 89, 184 N.R. 1, Cory J. for the majority states: Punitive damages may be awarded in situations where the defendant's misconduct is so malicious, oppressive and high-handed that it offends the court's sense of decency. Punitive damages bear no relation to what the plaintiff should receive by way of compensation. Their aim is not to compensate the plaintiff, but rather to punish the defendant. It is the means by which the jury or judge expresses its outrage at the egregious conduct of the defendant. They are in the nature of a fine which is meant to act as a deterrent to the defendant and to others from acting in this manner. It is important to emphasize that punitive damages should only be awarded in those circumstances where the combined award of general and aggravated damages would be insufficient to achieve the goal of punishment and deterrence.

In Whiten v. Pilot Insurance Co., [2002] 1 S.C.R. 595 at ¶ 69, 209 D.L.R. (4th) 257, 20 B.L.R. (3d) 165, 2002 SCC 18, Binnie J. for the majority notes that prior criminal proceedings can be of great importance in determining if punitive damages are appropriate, but they are not a complete bar to punitive damages.