What is the "robust and pragmatic" approach to determining causation in a motor vehicle accident?

In Goodman v. Viljoen, 2012 ONCA 896, Doherty J.A. wrote, at para. 76: The robust and pragmatic approach takes into account the nature of the factual issues underlying the causation question and the kind of evidence that the parties are reasonably capable of producing on those issues. The approach acknowledges that the causation inquiry is essentially a practical one based on the entirety of the evidence and made with a view to determining whether the plaintiff has established causation on the balance of probabilities and not to a scientific certainty.