Jury Questions

Jury questions are arguably the most important questions asked at a trial.


Liability may be admitted by the defence to avoid a potentially devastating issue or to avoid having to call an unlikeable defendant as a witness.

If liability is not admitted, consider whether causation is on a but for or material contribution test.

Contributory negligence

Where contributory negligence is alleged by the defence, it may be necessary to build in questions that ask about whether each side was potentially negligent, what the specific acts of negligence were and what percentage responsibility each party has.


Consider your pleading and all damages claimed.  Eliminate those which are not supported by the facts or are weak and distracting.  General damages for pain and suffering will be part of the case.  Lost income is common as are care costs.

Precedent Jury Questions

Click here to purchase sample MVA jury questions.  

These jury questions consider a motor vehicle accident where causation is an issue, there is lost income (past and future) and general damages for pain and suffering.

Ontario Civil Trial Manual

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This manual is trial information, not trial legal advice.

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