What is the test for awarding interest in a personal injury case?

The rationale for awarding interest has been stated in strong terms. "When, by virtue of the fraud or breach of fiduciary duty of the defendant, a plaintiff has been deprived of the use of his money or property and is obliged to resort to litigation to recover it, the inclusion of interest in the award is necessary in order to make the plaintiff whole. It is for this reason that it is proper to have such interest run from the time the plaintiff parted with the money or property on the basis of the defendant's fraud." (Nordahl v. Department of Real Estate (1975) 48 Cal.App.3d 657, 665, 121 Cal.Rptr. 794.)