As already explained, the Supreme Court of Canada adopted the ‘functional approach’ to the assessment of non-pecuniary general damages because there is no objective measure for the loss associated with pain and suffering. People react differently to pain, depending on their personal threshold. For that reason, Canadian courts have set a limit to the amount that can be claimed under this head of damages. In order to ensure a level of consistency and objectivity, they favour the use of factually comparable precedents. In McLaughlin v. Levesque, 2009 NBQB 85 paras 163-165, Justice LaVigne, before her appointment to the Court of Appeal, summarized the state of the law:
 When comparing cases, we must search for common factors that influence the awards, such as, the age of the plaintiff, the nature of the injury, the relative severity and duration of pain, disability, emotional suffering, and loss or impairment of enjoyment of life. The award must also be adjusted for inflation.
 The award does not depend only on the gravity of the injury. Compensation should be awarded 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. It should provide a fund of money to enhance the situation of that plaintiff. It must be remembered that non-pecuniary damages are awarded on a functional basis to the end of providing substitute pleasures for those which have been lost in order to ameliorate the plaintiff’s condition and make his or her life more bearable.
 General damages assessments are subjective in nature and are based on the plaintiff’s own experience of pain and suffering. It must manifest the individual plaintiff’s particular situation.
Inflation has been discussed previously. Other objective criteria are thus age, nature and effect of the injury.
In the same line of thought, some injuries are easier to assess than others. A broken bone can be seen on an x-ray; paraplegia or quadriplegia can be ascertained easily. It is not so for invisible injuries, like chronic pain and some emotional or psychological sequelae that typically rely on the subjective reports of the victim. In those cases, the credibility and reliability of the claimant are central to the assessment. In Boucher v. Doiron, 2000 NBCA 18 para 68, Justice Drapeau (as he then was) explained, for the unanimous bench:
 There is no doubt that an injured person is entitled to fair and reasonable compensation for losses attributable to his or her pain, even if there is no objective confirmation of any ongoing injury. Yet, there is much to be said in favour of moderation in the assessment of damages for personal injury when, as here, the reliability of the injured party’s account of effects of her pain is suspect and there is no objective evidence of any continuing injury.
That is where the evidence of a treating physician can become important: Baraly v. Bradley (1991), 117 NBR (2d) 413 para 53 (QB); Boucher v. Doiron (1999), 221 NBR (2d) 1 para 52 (QB); Firth v. Bossé, 2007 NBQB 349 paras 146-147; Webb v. Aviva Insurance Co., 2011 NBQB 98 paras 9-10 & 23-25; Matthews v. McIntyre, 2019 NBQB 127 paras 51-52. The absence of treatments can also play in the equation: Thibault v. Boudreau (1984), 59 NBR (2d) 113 para 23 (QB); Shaw v. Wawanesa Mutual Insurance Co., 2001 NBQB 17 para 16; Noël v. Royal and SunAlliance Insurance Co., 2005 NBQB 453 para 44; Bent v. MacFarlane, 2018 NBCA 17 para 87.
When assessing pain and suffering, courts will typically take a global approach, instead of trying to assess each injury separately. Conceptually, if a person already suffers from disabling pain in relation to one injury, the fact that another is sustained in the same accident would not likely have a corresponding effect on his or her level of pain. For example, a victim who has a daily dose of chronic back pain may only be marginally affected by an additional dose of elbow pain. In Melanson v. LeBlanc (1989), 99 NBR (2d) 177 para 8, the unanimous Court of Appeal explained the approach as follows:
 Each of the injuries and symptoms might, if considered separately, have resulted in a higher total award. There are, however, common features. For example, all have had an effect on her leisure activities and caused her discomfort at work. The court must base its award on the totality of those injuries and their effect upon a claimant rather than add up the sums it might have awarded for each separate injury or symptom.
However, like everything else, each case is assessed on its own facts. Although a person may continue to function despite constant pain, that ability may disappear if an impairment is added through paralysis. Thus, arguably, the assessment should start with the effects of the most severe injury up instead of searching for a common or middle ground between all the injuries.