What is the test for loss of capacity to perform work of economic value like housekeeping?

The loss of capacity to perform work of economic value like housekeeping, falls to be decided. In 2000 Madam Justice Huddart delivered reasons in McTavish v. MacGillivray. She recognized the importance of the law developing in the way it does so that disadvantages to lower income families and women do not persist. At para. 52 she said: 52 … Unless appropriate care is taken in evaluating the loss, lower income families and lower income women will be disadvantaged by a legal principle that affords full compensation only for those who were financially able to hire someone in the pre-trial period to perform household services or whose family members are able to take time off work to do necessary housekeeping tasks. She went on at paras. 63-64 to say: 63 As we have seen, it is now well established that a plaintiff whose ability to perform housekeeping services is diminished in part or in whole ought to be compensated for that loss. It is equally well established that the loss of housekeeping capacity is the plaintiff's and not that of the family. When family members have gratuitously done the work the plaintiff can no longer do and the tasks they perform have a market value, that provides a tangible indication of the loss the plaintiff has suffered and enables the court to assign a specific economic value in monetary terms to the loss. This does not mean the loss is that of the family members or that they are to be compensated. Their provision of services evidences the plaintiff's loss of capacity and provides a basis for valuing that loss. The loss remains the plaintiff’s loss of economic capacity. 64 This approach to valuation of the plaintiff’s loss has the advantage of encouraging family benevolence, without providing a windfall to the wrongdoer. It discourages the hiring of less satisfactory and perhaps more expensive substitute services. It allows a court to determine what services are reasonably necessary by reference to what services family members were prepared to provide...