In Western Australia, loss of capacity to care for a dependant (here, an aged parent) is compensable as a separate head of damage on Griffiths v Kerkemeyer principles, not merely as part of general damages. Burnicle v Cutelli is not followed. For mesothelioma claims, general damages of $130,000 were awarded in 2001, with a 15% contingency deduction applied to future loss of earnings to account for the intermittent nature of work in the building industry for a plaintiff aged 65-70.
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