In Sabourin Estate v. Watterodt Estate, 2005 BCCA 348, Lambert J.A., writing in dissent, notes that the law seems to have developed, and perhaps it is still developing, a number of different tests for determining the question of causation, depending upon the circumstances. He suggests that some may be inconsistent with others, that some may be irreconcilable, and that some tests may overlap with other tests. With much greater eloquence and descriptive language that I am able to provide, he suggests, inter alia, a variety of tests which might bear the following labels: 1. A wholly subjective test. 2. An objective test. 3. A subjective test measured against an objective standard.
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