The most cited test to determine whether an individual is totally disabled was stated by Laskin C.J. in Paul Revere at 546:

The test of total disability is satisfied when the circumstances are such that a reasonable man would recognize that he should not engage in certain activity even though he literally is not physically unable to do so. In other words, total disability does not mean absolute physical inability to transact any kind of business pertaining to one’s occupation, but rather that there is a total disability if the insured’s injuries are such that common care and prudence require him to desist from his business or occupation in order to effectuate a cure; hence, if the condition of the insured is such that in order to effect a cure or prolongation of life, common care and prudence will require that he cease all work, he is totally disabled within the meaning of health or accident insurance policies.

This test has been consistently followed in B.C.: Asselstine v. Manufacturers Life Insurance Co., 2005 BCCA 292 (B.C. C.A.); Halbauer v. Insurance Corp. of British Columbia, 2002 BCCA 5 (B.C. C.A.); Eddie v. UNUM Life Insurance Co. of America, 1999 BCCA 507(B.C. C.A.); Mathers v. Sun Life Assurance Co. of Canada, 1999 BCCA 292 (B.C. C.A.), leave to appeal to ref’d (2000), [1999] S.C.C.A. No. 334 (S.C.C.).

228 Being able to perform one or more important aspects of the occupation separately will not necessarily disqualify the insured from coverage; they do not need to be totally helpless. What matters is that the insured is unable to perform substantially all of the duties of that position: Paul Revere, at 545 – 546.

The Most Cited Disability Law Test