Discounting Awards For Multiple Injuries

What is the correct approach towards damages for pain, suffering and loss of amenity when multiple categories of injuries are suffered by a claimant?

This was the question considered by the Court of Appeal in Sadler v Filipiak (October 2011), in an appeal by the claimant against the general damages awarded by the trial judge.

The claimant's claim arose following a road traffic accident on 26 November 2006. The claimant had been the driver of a vehicle travelling with passengers to church when there was a frontal collision with the defendant's car travelling on the wrong side of the road in the opposite direction. One of the claimant's passengers was killed and the claimant suffered serious injuries, which were summarised as follows:

Transverse fracture of the mid femur on the left side Formatic dislocation of the right big toe Whiplash injury to the neck Blunt abdominal injury to the spleen Concussive head injury Multiple scarring to the face, arms and legs Blurred and patchy vision in the right eye...