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

In Willington v. Marshall (1994), 27 C.P.C. (3d) 34 (B.C.S.C.), Sinclair Prowse J. held that the judge should determine the pecuniary loss and the non-pecuniary damages before determining whether to award punitive damages: … the degree of punishment inflicted on the defendant by having to pay compensatory damages, including pecuniary and non-pecuniary damages, must first be determined before it is possible to consider whether any further penalty, by way of punishment should be imposed on the defendant and, if so, the additional amount that is required.