What is the test for the tort of intrusion upon seclusion?

The defendant points out that other jurisdictions have adopted a different interpretation of this cause of action. In the United States and in Australia, for example, it would appear that the tort of intrusion upon seclusion does include a requirement that the plaintiff show actual loss, as well as causation between the intrusion and the loss shown. The defendant refers to Grosse v. Purvis (2003) Q.D.C. 151, wherein an Australian court held that in addition to the three requirements listed above, they would require a fourth element to be proven: that the act “causes the plaintiff detriment in the form of mental, psychological or emotional harm or distress or which prevents or hinders the plaintiff from doing an act which she is lawfully entitled to do.” (par. 444).