What are contingencies when calculating an award for loss of earning capacity in a motor vehicle accident?

An award for loss of earning capacity is based on assumptions of future events, and therefore contingencies must be considered in the event that these assumptions may prove to be wrong. These contingencies are things that may affect future earnings, such as unemployment, illness, accidents and business depression. Dickson J. in Andrews v. Grant & Toy Alberta Ltd., 1978 CanLII 1 (SCC), [1978] 2 S.C.R. 229 at 253, 83 D.L.R. (3d) 452, provides some guide in adjusting for contingencies: First, in many respects, these contingencies implicitly are already contained in an assessment of the projected average level of earnings of the injured person, for one must assume that this figure is a projection with respect to the real world of work, vicissitudes and all. Second, not all contingencies are adverse…. Finally, in modern society there are many public and private schemes which cushion the individual against adverse contingencies. Clearly, the percentage deduction which is proper will depend on the facts of the individual case, particularly the nature of the plaintiff's occupation, but generally it will be small.