The inflation-adjusted maximum of $100,000 from 1978
The non-pecuniary maximum index is based on the Consumer Price Index for Canada (January 1978) given the judgment of the Honorable Mr. Justice Dickson (as he then was) in Andrews v. Grand & Toy Alberta Ltd.,  2 S.C.R. 229:1"The amounts of such awards should not vary greatly from one part of the country to another. Everyone in Canada, wherever he may reside, is entitled to a more or less equal measure of compensation for similar non-pecuniary loss. Variation should be made for what a particular individual has lost in the way of amenities and enjoyment of life, and for what will function to make up for this loss, but variation should not be made merely for the province in which he happens to live." (para. 93)
 Judgment dated January 19, 1978.