Is a plaintiff’s capacity to perform cleaning services compensable?
British Columbia, Canada
The following excerpt is from Ahmad v Pandher, 2017 BCSC 1732 (CanLII):
Housekeeping services have an economic value. The loss or impairment of a plaintiff’s capacity to perform them is, therefore, compensable: Harrington v. Sangha, 2011 BCSC 1035.
The Court of Appeal in Westbroek v. Brizuela, 2014 BCCA 48, noted at para. 77 that a cautious approach should be exercised when addressing this type of claim.
The governing principles that apply to awards for loss or impairment of housekeeping capacity were summarised by Newbury J.A. in Dykeman v. Porohowski, 2010 BCCA 36, where she noted that these claims must be carefully scrutinized: para. 29.
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