
Micallef v Distasio: Laser Burns, Ordinary Negligence, and a $50,000 Small Claims Judgment
A self-represented plaintiff recovered the full $50,000 Small Claims Court limit for burns and permanent pigmentation loss from a laser hair removal treatment, without an expert report on the standard of care. The Court reached that result by applying Ayana v Skin Klinic, the 2009 decision establishing that laser hair removal is not a medical procedure in Ontario. The defence bet that no plaintiff expert meant no case, and lost.










