In Gill v. Probert, 2001 BCCA 331, the court discussed the approach to be taken for past loss of earnings, stating that there was no need to distinguish between the approach to be taken to hypothetical events such as a loss of opportunity for past earnings and a loss of opportunity for future earnings. Hypothetical events need not be proved on a balance of probabilities, but rather they are to be given weight based on their likelihood.
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