What is the test for general damages for the loss of services provided by the parents of a deceased maid?

Nova Scotia, Canada


The following excerpt is from Leopold v. Knight, 1980 CanLII 2609 (NS SC):

Again, in the case of Landry v. Lamothe (1975), 1975 CanLII 1644 (NB QB), 14 N.B.R. (2d) 1, the learned trial Judge in awarding general damages to the parents stated at p. 4 as follows: There can be no doubt that the departure of the deceased has had the effect of depriving her mother and father of valuable services ordinarily performed by a maid. It is also clear that they very much needed these services or maid help. They cannot afford such help and since her departure, they are deprived of it. Under such circumstances, I have to conclude that the loss of such services is equivalent to monetary or pecuniary loss and is capable of a fair evaluation, always keeping in mind that such a young girl ought to attend school and generally leaves the house relatively young, either to pursue her studies or marry.

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