Section 72 of the Motor Accidents Act 1988 (NSW) does not limit compensation for paid domestic assistance, and it is not necessary that there be an existing liability to pay for future services, but the plaintiff must prove that he or she will actually incur liability to pay. The cost of employing someone to do gardening at the same level as the plaintiff did for pleasure or as a hobby does not justify an award under Griffith v Kerkemeyer. A trial judge assessing future economic loss must disclose the reasoning process, including what evidence was relied upon and how it was used.
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