The appropriate discount rate for future losses should be based on the rate of return on safe, readily realisable, long-term investments such as Commonwealth bonds or Australian Savings Bonds, not on the difference between inflation and market interest rates. The Cullen v Trappell adjustment for income tax notionally payable on the income from the invested lump sum is confined to the component for future economic loss. Where driving services are gratuitously provided by relatives and friends, the full cost of a paid driver cannot be recovered under Griffiths v Kerkemeyer principles. An error of approximately 4% in one component of a global damages award does not warrant reassessment where other components may be on the low side.
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