How have courts in England and Canada considered the tortious measure of damages in an action for misrepresentation?

In England and in Canada the authorities have consistently found that the proper approach is to apply the tortious measure of damages. This is an important distinction for this approach awards a measure of damages which places the plaintiff in the position he would have occupied if the statement had not been made rather than in that he would have occupied if the statement was true. This distinction is recognized in McConnel v. Wright, [1903] 1 Ch. 546. It is not an action for breach of contract, and, therefore, no damages in respect of prospective gains which the person contracting was entitled by his contract to expect come in, but it is an action of tort – it is an action for a wrong done whereby the plaintiff was tricked out of certain money in his pocket; and therefore, prima facie, the highest limit of his damages is the whole extent of his loss, and that loss is measured by the money which was in his pocket and is now in the pocket of the company. That is the ultimate, final, highest standard of his loss.