What is the range of damages for damages for defamatory communications?

Special damages may reflect a plaintiff’s lost income or revenue due to the defamatory communications. As Cory J. stated in Hill v. Church of Scientology of Toronto, 1995 CanLII 59 (SCC), [1995] 2 S.C.R. 1130, at para. 169, “special damages for pecuniary loss are rarely claimed and often exceedingly difficult to prove.”