When will a plaintiff receive a management fee or investment counselling fee in a serious personal injury case?

The seminal decision on the circumstances in which an award for management fees should be made is Mandzuk v. I.C.B.C., 1988 CanLII 16 (SCC), [1988] 2 S.C.R. 650. At ¶2 Sopinka J. stated: The issue in this appeal is whether or not in serious personal injury cases an amount for an investment-counselling fee should be awarded the plaintiff. This is essentially a question of fact in each case. The only principle that appears to be applicable is that the defendant must take the plaintiff as he finds him, including his state of intelligence. Whether this is low by reason of the injuries complained of or its natural state, a management fee or an investment counselling fee should be awarded if the plaintiff’s level of intelligence is such that he is either unable to manage his affairs or lacks the acumen to invest funds awarded for future care so as to produce the requisite rate of return.