What is the difference between the total lifestyle approach for future care and the basic necessities?

British Columbia, Canada


The following excerpt is from Coulter v. Ball, 2002 BCSC 1740 (CanLII):

One method, the total lifestyle approach, awards the full award for future care with no deduction in respect to the provision of basic necessities. A percentage attributable to the necessities of a person in a normal state is then deducted from the award for loss of prospective earnings. This was the approach taken and endorsed in Andrews v. Grand & Toy Alberta Ltd. (1978), 1978 CanLII 1 (SCC), 83 D.L.R. (3d) 452 (S.C.C.).

The second method, the additional costs method, awards the full amount for loss of prospective earnings. The cost of basic necessities is from the future care award. The additional costs method was utilized in Arnold et al v. Teno et al (1978), 1978 CanLII 2 (SCC), 83 D.L.R. (3d) 609 (S.C.C.).

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