no 696,  R.J.Q. 2765 (C.A.)), New Brunswick (see Stock-
ford v. Johnston Estate,  N.B.J. No. 122, 2008 NBQB 118,
335 N.B.R. (2d) 74 ), and Australia (see Cattanach v. Melchior,
 H.C.A. 38, 199 A.L.R. 131) — have allowed some form of
recovery for the cost of raising a healthy child,2 Ontario courts
have, to date, generally not followed that approach in involun-
tary parenthood cases: see Paxton v. Ramji,  O.J. No.
3694, 2008 ONCA 697, affg (2006), 92 O.R. (3d) 401,  O.J.
No. 1179 (S.C.J.), at n. 7. In the oft-cited case of Kealey v. Bere-
zowski (1996), 30 O.R. (3d) 37,  O.J. No. 2460 (Gen. Div.),
Lax J. discussed the question at length and held that, while the
general principles for the award of damages for child-rearing
costs should evolve on a case-by case basis [at para. 82],
The responsibilities and the rewards [of rearing a child] are inextricably
bound together and do not neatly balance one against the other, at least not
in the case of children. Who can say whether the time, toil and trouble,
or the love, guidance and money which parents devote to a child’s care and
upbringing, will bring rewards, tangible or intangible, today, tomorrow
or ever. No court can possibly determine this in any sensible way. Nor
should it attempt to do so . . . The responsibilities and the rewards cancel
each other out.
 The issue of damages in involuntary parenthood cases
was extensively considered by the House of Lords in McFarlane
v. Tayside Health Board (Scotland),  4 All E.R. 961, 
2 A.C. 59 (H.L.) and again in Rees v. Darlington Memorial Hospital NHS Trust,  UKHL 52,  1 A.C. 309 (H.L.). Both
of these cases dealt with the most common form of such claims,
that is, those brought by one or both parents against third-party
health care providers.
 In McFarlane, the plaintiff’s husband had a vasectomy and
was advised that his sperm count was nil and that contraceptive
precautions were no longer necessary. The couple acted on that
advice and the plaintiff subsequently became pregnant and delivered a healthy child. The parents alleged that they had suffered
loss as a result of the health board’s negligence. The plaintiff
sought damages from the health board for pain and suffering arising out of pregnancy and labour as well as for the financial consequences of the parents’ duty to raise the child, whom they loved
and cared for as an integral part of their family.
2 The result in Cattanach was subsequently modified by legislation in three
Australian states, essentially restricting recovery for involuntary
parenthood to the extra cost of raising a child born with a disability: see
B. Feldthusen, “Supressing Damages in Involuntary Parenthood Actions”
(2014), 29 Can. J. Family Law 11, n.12.