What is the test for deducting from a plaintiff's income from her income as a result of her disability?

Ontario, Canada


The following excerpt is from Walker v. Ritchie, 2005 CanLII 13776 (ON CA):

The trial judge recognized the need to adjust for both positive and negative contingencies. He cited Andrews v. Grand & Toy Alberta Ltd., 1978 CanLII 1 (SCC), [1978] 2 S.C.R. 229, for the principle that such deductions depend upon the circumstances of the particular plaintiff but, generally, will be small.

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