When dealing with punitive damages, when dealing with compensatory damages, does the court have a much greater scope and scope on appeal?

Unlike the situation when a court is reviewing compensatory damages, when dealing with punitive damages courts have a much greater scope and discretion on appeal: Hill v. Church of Scientology of Toronto, 1995 CanLII 59 (SCC), [1995] 2 S.C.R. 1130 at para. 197.

As the trial judge recognized, punitive damages will rarely be awarded in a case involving breach of contract. In fact, they can only be recovered if the plaintiff can establish a separate actionable wrong – i.e. the breach of a different obligation under the contract or other duty, such as a fiduciary obligation.[4] This is because in contract cases, the remedies open to the plaintiff are only those that arise from the contractual relationship, whereas in tort cases the injured party is entitled to be made whole: see Vorvis v. Insurance Corp. of British Columbia, 1989 CanLII 93 (SCC), [1989] 1 S.C.R. 1085 at 1106‑1107.