How have courts interpreted the doctrine of a "phantom vehicle" in a motor vehicle accident claim?

More recently, Macdonell J. in Wong v. Hunt, [1985] B.C.W.L.D. 2715, B.C.S.C., Vancouver No. B832027, 21st June 1985 (not yet reported), followed the reasoning of McLachlin J. in Jamt v. Schuurman, supra. He found as a fact that the plaintiff was unaware of any unidentified motorist when she instructed counsel and the issue of a "phantom vehicle" was raised by the adjuster. I recognize that where the plaintiff has known of the existence of an unidentified driver from the date of the accident, the discretion vested in the court must be exercised far more sparingly and with greater reluctance than where the plaintiff is unaware of the unidentified motorist until later.