British Columbia courts have recognized the principle that loss
of housekeeping ability can have an economic value for which
damages may be awarded. However, how that value should be assessed
and whether a separate award should be made continues to be the
subject of judicial discussion. As the Court of Appeal in the
recent case of Kim v. Lin, 2018 BCCA 77
[Kim] said, valuing loss of housekeeping capacity
continues to be a "somewhat vexing issue."
Two recent appellate decisions provide some useful analysis of
this issue. In the aforementioned Kim decision as well as
in the further decision of Riley v. Ritsco, 2018
BCCA 366 [Riley], the Court of Appeal considered
(a) when damages should be awarded for loss of housekeeping
capacity and (b) whether that loss should be assessed as a part of
the non-pecuniary damages award or under a separate head of
damages. With respect to the latter issue, the Court considered an
important factor to be the plaintiff's need-to-date
