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I wouldn't be surprised to learn that the ABI's position will be that as there is no loss in the case of a deceased person without dependants, and the civil justice system does not exist to impose punitive damages on a tortfeasor, there cannot be any justification to maintain an award in respect of bereavement damages beyond the reasonable funeral costs incurred and thus the statutory figure should be reduced from c. £13,000 to c. £3,500.