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Obligations for Reasonable Mitigation

Duty to avoid unnecessarily large losses or damages

Page last modified : December 06 2023

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What Is the Mitigation Principle?

The duty to mitigate entails the person who has been harmed taking reasonable steps to limit the harm. Failure to mitigate may reduce the amount recoverable through litigation.

Understanding the Duty to Mitigate Losses by Minimizing Losses, as well as the Required Standard of Efforts to Do So

In a conscientious society, reasonably minded people desire to avoid waste; as a result, the law imposes the mitigation principle, which is a duty to mitigate, on a harmed party. This legal notion demanding mitigation measures applies to all areas of law, including tort law, contract law, employment law, and construction law, among others.

The Law

The notion of mitigation was fully explained, but the Supreme Court stated in general in Southcott Estates Inc. v. Toronto Catholic District School Board, [2012] 2 S.C.R. 675, that:

[23] This Court in Asamera Oil Corp. v. Seal Oil & General Corp., 1978 CanLII 16 (SCC), [1979] 1 S.C.R. 633, cited (at pp. 660-61) with approval the statement of Viscount Haldane L.C. in British Westinghouse Electric and Manufacturing Co. v. Underground Electric Railways Company of London, Ltd., [1912] A.C. 673, at p. 689:
The fundamental basis is thus compensation for pecuniary loss naturally flowing from the breach; but this first principle is qualified by a second, which imposes on a plaintiff the duty of taking all reasonable steps to mitigate the loss consequent on the breach, and debars him from claiming any part of the damage which is due to his neglect to take such steps.
[25] On the other hand, a plaintiff who does take reasonable steps to mitigate loss may recover, as damages, the costs and expenses incurred in taking those reasonable steps, provided that the costs and expenses are reasonable and were truly incurred in mitigation of damages (see P. Bates, “Mitigation of Damages: A Matter of Commercial Common Sense” (1992), 13 Advocates’ Q. 273). The valuation of damages is therefore a balancing process: as the Federal Court of Appeal stated in Redpath Industries Ltd. v. Cisco (The), 1993 CanLII 3025 (FCA), [1994] 2 F.C. 279, at p. 302: “The Court must make sure that the victim is compensated for his loss; but it must at the same time make sure that the wrongdoer is not abused.” Mitigation is a doctrine based on fairness and common sense, which seeks to do justice between the parties in the particular circumstances of the case.

As a result, the responsibility to mitigate requires a person who has been damaged to lessen the harm incurred. Failure to mitigate the harm may, and almost certainly will, reduce the amount that the wrongdoer will owe the harmed person in a culpability determination at a court trial. As the Supreme Court indicated above in the Southcott Estates case, where a failure to mitigate occurs, it is the Plaintiff’s failure to act reasonably to lessen the loss that causes a portion of the injury. Simply put, if the Defendant does anything wrong that causes harm to the Plaintiff, the Defendant is only liable for the portion of the harm that is directly caused by the Defendant’s conduct and not for the remainder of the harm.

Summary Comment

The law required that a Plaintiff (or, in the case of a counterclaim against the Plaintiff, a Defendant) take reasonable steps to mitigate, or decrease, losses. When a person fails to take reasonable steps to mitigate (reduce losses), the law will disallow claims, or the amounts within claims, that arose as a result of the failure to mitigate, whereas the law views the losses that arise as a result of the victim’s inaction rather than the wrongdoer’s action. When the Defendant alleges failure to mitigate, it is the Defendant’s responsibility to prove that the Plaintiff failed to mitigate and that a reasonable opportunity to mitigate was available; additionally, the Plaintiff is required to take reasonable steps to mitigate.

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 shemesh Legal Offices attends:
Landlord Tenant Board
(Toronto South LTB)
15 Grosvenor Street
Toronto, Ontario,  M7A 2G6

 shemesh Legal Offices attends:
Superior Court of Justice
(Kitchener Waterloo Courthouse)
85 Frederick Street
Kitchener, Ontario,  N2H 0A7

Ian Shemesh represented us in a landlord and Tenant Board hearing against our tenant. He was very quick on his feet and prepared. He knew exactly what he was doing and what he was talking about. He was very good with us and he was with us every step of the way. I would highly recommend him and his team.
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