What is the duty of a plaintiff to mitigate?

32. The leading case on a plaintiff’s duty to mitigate is Red Deer College v. Michaels 1975 CanLII 15 (SCC), [1976] 2 S.C.R. 324. The court held that a plaintiff ought to be put in as good a position as he or she would have been if there had been proper performance of the contract by the defendant. However, there is no obligation on the defendant to compensate a plaintiff for avoidable losses. The case states at page 331: In short, a wronged plaintiff is entitled to recover damages for the losses he has suffered but the extent of those losses may depend on whether he has taken reasonable steps to avoid their unreasonable accumulation. He may not have obtained other employment, and the question whether he has stood idly or unreasonably by, or has tried without success to obtain other employment would be part of the case on damages. If it is the defendant’s position that the plaintiff could reasonably have avoided some part of the loss claimed, it is for the defendant to carry the burden of that issue, subject to the defendant being content to allow the matter to be disposed of on the trial judge’s assessment of the plaintiff’s evidence on avoidable consequences.