Where a plaintiff has a pre-existing degenerative condition that increases susceptibility to injury, and the defendant's evidential burden under Watts v Rake is not discharged to disentangle the disabilities, the pre-existing condition must nonetheless be reflected in increased allowances for contingencies under Malec v J C Hutton Pty Ltd. These allowances must be applied differentially across heads of damage, with greater allowances for future economic loss than for general damages and other future heads. A trial judge who attributes a condition entirely to the tortious injury, when the medical evidence properly understood shows a pre-existing component, commits an error requiring appellate correction on damages.
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