What is the burden of mitigation for a plaintiff?

While a plaintiff has the burden of proving both the fact that he has suffered damage and the quantum of that damage, the burden of proof moves to the defendant if he alleges that the plaintiff could have and should have mitigated his loss. See Janiak v. Ippolito, 1985 CanLII 62 (SCC), 31 C.C.L.T. 113 at para. 32. The defendants did not satisfy this burden at trial. Evidence was not called to show how and to what extent the loss sustained by the plaintiffs could have been minimized. This of course is to be contrasted with my earlier analysis in relation to the plaintiffs' degree of contributory negligence. However, having completed an analysis of actual and prospective damages, I am not persuaded that the plaintiffs' damages are to be further reduced on account of the principle of mitigation.