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Vorvis v. Insurance Corporation of British Columbia, [1989] 1 S.C.R. 1085

Facts:

P was wrongfully dismissed from work. At work supervisor was oppressive and made life horrible. P found work 7 months later. D paid one month severance

Issue(s):

Can punitive or aggravated damages by awarded for wrongful dismissal of employment?

Ratio:

The claim for compensation (aggravated damages) for mental distress must be grounded in an independently actionable conduct. NOTE: due to Whiten you no longer need an actionable wrong

Analysis:

Role of aggravated damages is compensatory (for plaintiff) – increased over and above the normal economic loss.
Punitive damages may only be employed in circumstances where the conduct giving cause for complaint is of such a nature that it merits punishment. – punish behaviour.


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