What are the principles applicable to the assessment of claims and awards for the cost of future care?

The principles applicable to the assessment of claims and awards for the cost of future care might be summarized as follows: • the purpose of any award is to provide physical arrangement for assistance, equipment and facilities directly related to the injuries; • the focus is on the injuries of the innocent party... Fairness to the other party is achieved by ensuring that the items claimed are legitimate and justifiable; • the test for determining the appropriate award is an objective one based on medical evidence; • there must be: (1) a medical justification for the items claimed; and (2) the claim must be reasonable; • the concept of "medical justification" is not the same or as narrow as "medically necessary"; • admissible evidence from medical professionals (doctors, nurses, occupational therapists, et cetera) can be taken into account to determine future care needs; • however, specific items of future care need not be expressly approved by medical experts... It is sufficient that the whole of the evidence supports the award for specific items; • still, particularly in non-catastrophic cases, a little common sense should inform the analysis despite however much particular items might be recommended by experts in the field; and • no award is appropriate for expenses that the plaintiff would have incurred in any event. I have also considered that the costs awarded must be fair to both parties: Andrews v. Grand & Toy Alberta Ltd., 1978 CanLII 1 (SCC), [1978] 2 S.C.R. 229 at 241–42.