Does the collateral benefit principle apply directly to a per quod action?

British Columbia, Canada

The following excerpt is from A.G. Can. v. Szaniszlo, 1985 CanLII 321 (BC SC):

Secondly, our Court of Appeal in Davidson v. Pun has applied the collateral benefit principle directly to a per quod action and refused to allow recovery for payments made in the nature of insurance. The reasoning of the court, with which I respectfully concur, is that a payment in the nature of insurance is hardly the kind of loss an employer suffers from the loss of an employee’s services. This entirely logical result avoids the risk of double jeopardy. No system of law should tolerate a system where the employee recovers his payments in the way of insurance from the wrongdoer, and the wrongdoer may be liable again for the same amount in the per quod action. That is not the result in this case only because the injured serviceman did not claim them all.

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