In Vorvis v. Insurance Corporation of British Columbia (1989), 1989 CanLII 93 (SCC), 36 B.C.L.R. (2d) 273 (S.C.C.), McIntyre J., speaking for the majority, held that although available, punitive damages for a breach of contract are rare. He said at p. 289: ...an award of punitive damages should always receive the most careful consideration and the discretion to award them should be most cautiously exercised.
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