In a subsequent decision, Perren v. Lalari, 2010 BCCA 140 at para. 32, Garson J.A. restated the proposition that the plaintiff must prove that there is a real and substantial possibility of a future event leading to an income loss and, once proven, then the plaintiff may prove the quantification of the loss of earning capacity on either an earnings approach or a capital asset approach. Where the loss is not readily measurable, the capital asset approach will be more useful than the earnings approach.
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