What is the test for awarding punitive damages in a sexual assault case?

In assessing damages, “a trial judge should consider how the combination of compensatory damages, punitive damages, and any other punishment related to the same misconduct contributes to achieving the objectives of retribution, deterrence, and denunciation. For example, in John Doe v. O’Dell, the defendant priest was sentenced to 30 months’ imprisonment for sexual assault and gross indecency. Swinton J. determined this was not a case where punitive damages should be awarded as the defendant had been punished in the criminal system. Further, Swinton J. cited the large sum in damages as a deterrence for similar misconduct.