What is the test for the "rough upper limit" of damages in a personal injury action?

As Sopinka J. noted in ter Neuzen v. Korn, supra, at para. 108: ... Awards for non-pecuniary loss are inherently arbitrary or conventional. Therefore, once the future care of the plaintiff is adequately addressed, it is more appropriate to consider policy issues in limiting damage awards. In particular, the social burdens of excessive awards must be considered, as extravagant claims can pose a significant burden on society. ... In my view, the very serious policy concerns expressed by the imposition of the "rough upper limit" are an overriding consideration and are cause to depart from the general rule that the lex loci delicti rule should apply. It would be unjust, in my view, to apply any law of damages other than that of British Columbia to an action involving only British Columbia residents. It is obvious that British Columbia is the only jurisdiction that will be affected by an award of damages.