Is loss of homemaking capacity a separate non-pecuniary loss from the award for pain, suffering and loss of enjoyment and amenities of life?

While Justice Wakeling in his dissenting judgment advocated the inclusion of any award for loss of homemaking capacity within the award for non-pecuniary damages for pain, suffering and loss of enjoyment and amenities of life, the majority held that the award for loss of homemaking services prior to trial must be identified as a separate non-pecuniary loss. In many cases the bottom line may be no different for the claimant but, as Justice Vancise noted, the identification of elements of an award where possible is consistent with the direction in Andrews v. Grand & Toy Alberta Ltd., 1978 CanLII 1 (SCC), [1978] 2 S.C.R. 229, and is helpful to the litigants and the courts in understanding the award.