Is a plaintiff entitled to a replacement cost for her loss of housekeeping capacity?

In McTavish v. MacGillivray, 2000 BCCA 164, Huddart J.A. held that the loss of housekeeping capacity is to be compensated for on a replacement cost basis. That is so even when the services are performed voluntarily or gratuitously by other family members. The trial judge in McTavish made an award for loss of past housekeeping capacity that he characterized as “pecuniary general damages”. Huddart J.A. concluded that was an acceptable characterization of such an award. At para. 69, she also noted that the loss of housekeeping capacity may affect the amount of non-pecuniary damages in at least two circumstances: first, for those housekeeping tasks that the plaintiff performed but with increased difficulty or pain; and second, for those tasks that were left undone because they were beyond the plaintiff’s capacity.