In Carson v. Kearney (Town) (Ont CA, 2016) is useful authority for the proposition that impecuniosity can act as a limiting factor on a party's duty to mitigate damages:
 The duty to mitigate required that the respondents take reasonable steps to mitigate their damages. The duty to mitigate, however, does not require the injured party to spend money that it does not have, especially when it is the conduct of the tortfeasor that has left the injured party without funds. We would not interfere with the damages award.
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