What is the measure of damages in a conversion action?

Manitoba, Canada


The following excerpt is from Steiman v. Steiman, 1982 CanLII 2973 (MB CA):

On the appeal, counsel for the plaintiff submitted that the measure of damages is the same in conversion as in detinue and the learned trial judge was of the same view. There have been some judicial pronouncements to the same effect. Thus, for example, Lord Goddard C.J. in Sachs v. Miklos et al., [1948] 2 K.B. 23 at p. 39, said: It seems to me that in assessing damages for detinue or for conversion (and, for myself, I do not see where the distinction is to be drawn between those two causes of action for this purpose) the damages are not necessarily and in all cases the value of the goods at the date of judgment.

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