What is the impact of not pursuing reasonable recommended courses of medical treatment on damages?

Failure to mitigate by not pursuing reasonable recommended courses of medical treatment may result in reduction of damages. A leading case on this issue is Chiu v. Chiu, 2002 BCCA 618, in which the court states at para. 57:

The onus is on the defendant to prove that the plaintiff could have avoided all or a portion of his loss. In a personal injury case in which the plaintiff has not pursued a course of medical treatment recommended to him by doctors, the defendant must prove two things: (1) that the plaintiff acted unreasonably in eschewing the recommended treatment, and (2) the extent, if any, to which the plaintiff’s damages would have been reduced had he acted reasonably. These principles are found in Janiak v. Ippolito, 1985 CanLII 62 (SCC), [1985] 1 S.C.R. 146.

In Gregory v. Insurance Corporation of British Columbia, 2011 BCCA 144 at para. 56, the court further articulates that the test is a “subjective/objective test … [t]hat is whether the reasonable patient, having all the information at hand that the plaintiff possessed, ought reasonably to have undergone the recommended treatment.”