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Damages - Punitive (4). Beaumont v. Beaumont
In Beaumont v. Beaumont (Ont CA, 2025) the Ontario Court of Appeal considered punitive damages:[16] Regarding the quantum of punitive damages, the appellants assert that they are excessive and the ratio of punitive damages to compensatory damages in this case demonstrates the disproportionality or irrationality of the punitive damages award. This submission finds no support in the law of punitive damages. As the Supreme Court stated in Whiten v. Pilot Insurance Co., 2002 SCC 18, at para. 92, “punitive damages are directed to the quality of the defendant’s conduct, not the quantity (if any) of the plaintiff’s loss.” See also Hill v. Church of Scientology of Toronto, 1995 CanLII 59 (SCC), [1995] 2 S.C.R. 1130, at para. 196.
[17] There is no basis for this court to interfere with the quantum of punitive damages awarded. Punitive damages awards are “designed to punish wrongful conduct, to denounce that misconduct, and to act as a deterrent for future misconduct. […] Deterrence is impossible unless the punishment is meaningful”: Baker v. Blue Cross Life Insurance Company of Canada, 2023 ONCA 842, at paras. 32 and 34. The punitive damages awarded in this case are reasonable, proportional, and rational.
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