The difficulty in making a fair assessment under this head of damages was highlighted by Finch J.A. in Pallos v. Insurance Corp. of British Columbia,  W.W.R. 728 (B.C.C.A.), when he concluded the various methods of assessment are “equally arbitrary” (para. 43). He then concluded that “[i]t has, however, often been said that the difficulty of making a fair assessment of damages cannot relieve the court of its duty to do so” (para. 43).
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