What is the test for loss of earnings or capital asset in a personal injury action?

British Columbia, Canada


The following excerpt is from Erwin v. Buhler, 2017 BCSC 362 (CanLII):

The plaintiff has not proven a real or substantial possibility that he might lose income in the future. The plaintiff must establish the real and substantial possibility of such a loss before the court can consider loss of earning capacity on an earnings approach or the capital asset approach: see Perren v. Lalari, 2010 BCCA 140 at para. 32.

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