What is the pleading of a claim for past in-trust services?

One aspect of this claim that is not directly in issue on this appeal, but is of some significance, is the question of the extent to which a claim for past in-trust services ought to be pleaded. The claim is addressed under the heading of special damages which normally requires that the claim be specifically pleaded as is the case with out-of-pocket expenses. The trial judge relied on Frers v. De Moulin [2002 BCSC 408] for the proposition that an in-trust claim does not have to be specifically pleaded and Frers was not challenged by the appellant in this case. Nonetheless, it appears to me that a claim of this nature ought to be pleaded to provide a degree of specificity to the claim. As I have indicated, the pleading point is not specifically put in issue on this appeal, but in my view, good practice suggests that in future cases it ought properly to be pleaded.