In a decision handed down by the NSW Court of Appeal on 16th February 2012 in Allianx Australia Insurance -v- Kerr;

the Court found that the injured person required someone to provide two hours of cleaning per week inside her home and two hours for external work, making a total of four hours of unpaid care each week.

In this case, the main provider of gratuitous assistance was a long-term friend, but not a family member.  He had no legal obligation to provide the assistance, or to continue doing it.

The Court determined that where the main provider of gratuitous assistance is not a family member, the Court does not have to find that he would stop doing it, and that domestic assistance would only be provided by a paid carer in the future, before making an allowance of damages for future domestic assistance on a commercial basis.