What is the quantum of damages for the spouse of a substitute carer?

The factors to be considered in assessing such claims are set out in O’Connell v. Yung, 2010 BCSC 1764, para. 90: (a) where the services replace services necessary for the care of the plaintiff; (b) if the services are rendered by a family member, here the spouse, are they over and above what would be expected from the marital relationship? (c) quantification should reflect the true and reasonable value of the services performed taking into account the time, quality and nature of those services. In this regard, the damages should reflect the wage of a substitute caregiver. There should not be a discounting or undervaluation of such services because of the nature of the relationship; (d) it is no longer necessary that the person providing the services has foregone other income and there need not be payment for such services.