The Griffiths v Kerkemeyer doctrine is confined to gratuitous services rendered by friends or relatives and does not extend to services provided by publicly or privately funded charitable institutions. Claims for services rendered by charitable institutions must be assessed under the Espagne principles, under which the character and purpose of the benefit — including the intent of the provider — determines whether the benefit reduces the plaintiff's damages. Where a charitable institution provides services free of charge without imposing any obligation to pay, those services constitute subventions given out of benevolence that are not recoverable from the tortfeasor.
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