The following excerpt is from Quebec (Public Curator) v. Syndicat national des employés de l'hôpital St-Ferdinand, [1996] 3 SCR 211, 1996 CanLII 172 (SCC):
73. The so‑called conceptual approach considers the components of a human being to have purely objective value, which is expressed in a specific monetary amount. The major disadvantage of this extremely simple method is that it fails to take into account the victim’s specific situation. It has been criticized as being an “unsubtle” solution: Andrews v. Grand & Toy Alberta Ltd., supra, at p. 261.
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