What is the test for calculating loss of future income for a plaintiff in a motor vehicle accident?

British Columbia, Canada


The following excerpt is from Dikey v. Samieian, 2008 BCSC 604 (CanLII):

See also Conklin v. Smith, 1978 CanLII 181 (SCC), [1978] 2 S.C.R. 1107, 6 B.C.L.R. 362: If, however, the plaintiff was not gainfully employed at the time of the accident but intended to be and was capable of being so gainfully employed thereafter, the court must made a reasonable allowance for the probable loss of future income due to the plaintiff having been deprived of that opportunity. Such allowance has been made when the plaintiff was very far from having been engaged in any gainful employment…. …it is the duty of a court to assess such sum for loss of future income as may be determined from a reasonable appraisal of the evidence.

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