As a general rule, we take account of contingencies that might affect future earnings. This is so despite the fact that these contingencies are already implicitly contained in an assessment of the projected average level of earnings of the person wronged. Not all contingencies are adverse. And some public and private schemes cushion individuals against adverse contingencies. The percentage deduction is generally small: Andrews v. Grand & Toy Alberta Ltd., 1978 CanLII 1 (SCC), [1978] 2 S.C.R. 229, at p. 253.
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