What is the test for assessing future income loss damages in a motor vehicle accident?

In conclusion, at para. 27 on p. 269, the court said: It does not appear that the trial judge had his attention drawn to any of these cases, or to the approach they suggest. These cases all treat a person’s capacity to earn income as a capital asset, whose value may be lost or impaired by injury. It is a different approach from that taken in Steenblok v. Funk (supra), and similar cases, where the court is asked to determine the likelihood of some future event leading to loss of income. Those cases say, if there is a “real possibility” or a “substantial possibility” of such a future event, an award for future loss of earning may be made. There is nothing in the case law to suggest that the “capital asset” approach and the “real possibility” approach are in any way mutually exclusive. They are simply different ways of attempting to assess the same head of damages, future loss of income. It is to be regretted that plaintiff’s counsel did not advance the case at trial using both approaches in the alternative.