In 1957, Coyne (plaintiff), a practicing physician and surgeon, sustained a whiplash injury when his vehicle was struck in the rear by a vehicle driven by Campbell (defendant). Thereafter, Coyne received medical treatment, physiotherapy, and care from his professional colleagues and nurse, and incurred no out-of-pocket expenses. Coyne sued Campbell for negligence and requested $2,235 in special damages for the medical expenses and nursing care provided. The trial court held that the amount was not allowable and that Coyne was not entitled to any recovery. Coyne appealed.