What are the elements applicable to an assessment of future care costs?

British Columbia, Canada


The following excerpt is from Patterson v Gauthier, 2019 BCSC 633 (CanLII):

In Manky v. Scheepers, 2017 BCSC 1870, Justice Kent noted that the key elements applicable to an assessment of the costs of future care are that there be evidence of the amounts claimed, evidence of medical justification for the amounts and that the items claimed be reasonable:

The principles applicable to the assessment of claims and awards for the cost of future care are summarized in Kallstrom v. Yip, but I will not repeat them here. Suffice it to say admissible evidence must be tendered to substantiate not only the amount that will be incurred but also the medical justification and the reasonableness of items claimed. No such evidence has been tendered and no award is made under this heading.

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