Section 87(1) of the Trade Practices Act 1974 (Cth) empowers a court to award only part of an indivisible loss causally connected with a s 52 contravention, where the plaintiff's own independent conduct also contributed to the loss. The 'all or nothing' rule under s 82(1) does not prevent apportionment under s 87(1). The divisibility or indivisibility of the loss is not the criterion for whether apportionment is available. Once proceedings of the relevant kind are before the court, the court has all the powers s 87 encompasses and may mould relief to achieve a fair result, whether or not the plaintiff presses for a s 87 order.
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