Is a plaintiff entitled to a separate award for loss of future wages for retraining?

British Columbia, Canada


The following excerpt is from Palangio v Tso, 2017 BCSC 1573 (CanLII):

While I agree with the defendants that the trial judge should not have made a separate award for loss of future wages, it would not have been improper for her to have taken the possibility of retraining into account when assessing loss of future earning capacity. As noted by Mr. Justice Hall in the following passage in Pett v. Pett, 2009 BCCA 232, 93 B.C.L.R. (4th) 300, the ultimate task is to quantify the financial harm to be sustained by the plaintiff:

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