What is the test for punitive damages in sexual assault cases?

As noted by La Forest J. in Norberg v. Wynrib, 1992 CanLII 65 (SCC), [1992] 2 S.C.R. 226 at pp. 263-64, the role of punitive damages is to punish and deter the wrongdoer, “making an example of him or her in order to deter others from committing the same tort”. As McLachlin J., (as she then was), emphasized in Norberg, punitive damages may be important in sexual assault cases to deter others. The role of deterrence, however, should not be emphasized at the expense of proper quantification of compensatory damages.[2]