Where the evidence cannot identify the time at which or the extent to which progressive physical incapacity will impact upon a plaintiff's capacity to work, there is no basis upon which a multiplicand can be identified for actuarial calculation, but that does not preclude an award for loss of future earning capacity; the jury may assess the degree of risk and determine a reasonable sum without actuarial tables. Trial judges directing juries on assessment of risk of future loss are not required to replicate the language of percentage probabilities used in Malec v J.C. Hutton Pty Ltd; directing the jury to assess risk by reference to 'degrees of probability or likelihood' is sufficient.
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