What is the test for assessing future damages in a personal injury case?

19 First, damages are assessed and not calculated. Since it is impossible to calculate the exact amount of money that will be needed in the future, courts have to rely on actuarial evidence: Andrews v. Grand & Toy Alberta Ltd., 1978 CanLII 1 (SCC), [1978] 2 S.C.R. 229, at pp. 236‑37. Actuarial evidence is itself based on experience and not on individual circumstances. Future costs and loss of future earnings are amounts that are estimated because, by definition, they are not yet incurred or earned. Although this hypothesis may seek to simulate reality, it remains notional. Courts can only provide the victim with an adequate amount to cover the loss caused by the defendant. There is no assurance that the amount will cover the actual costs of care that become incurred nor is the defendant guaranteed that he or she is not disbursing more than the strict minimum that becomes necessary to cover the victim’s loss. In assessing damages, courts do not take into consideration what victims actually do with the award. The fact that the respondent here had to wait for almost five years before management fees were assessed creates an atypical situation, but these exceptional circumstances should not justify a departure of the usual rules. Notional amounts cannot be mixed with actual amounts when assessing future damages.