What is the test for adding “one figure” to the damages of a plaintiff who was physically abused by the Church of Scientology?

That “one figure” may be augmented in appropriate cases if the circumstances warrant “aggravated damages”; for example, where the defendant’s conduct has been “particularly high-handed or oppressive”, thereby increasing a plaintiff’s “humiliation, anxiety, grief, fear and the like”. Such aggravated damages are compensatory in nature, and “take into account the additional harm caused to the plaintiff’s feelings”. See Hill v. Church of Scientology of Toronto, 1995 CanLII 59 (SCC), [1995] 2 S.C.R. 1130, at paragraph 188.