Because she has no recent employment history and was not employed at the time of the accident, her claim for past loss is, analytically, akin to her claim for future loss. Both counsel agreed that the law that governs the proper assessment of her future loss is that revealed by our Court of Appeal in Perren v. Lalari, 2010 BCCA 140, 3 B.C.L.R. (5th) 303. In my view those principles are also applicable to her claim for past loss of income in the circumstances of this case.
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