Callahan, J.
The issue presented in this appeal is whether the trial court properly instructed the jury on the doctrine of mitigation of damages. The named plaintiff, Rebecca Preston, brought this action to recover for personal injuries arising from an automobile accident allegedly caused by the negligence of the named defendant, Anthony J. Keith.1 Finding that the plaintiff was 50 percent contributorily negligent, the jury returned a verdict for her in the amount of $5593.50. The plaintiff thereafter filed a motion for additur and a motion to set aside the verdict and for a new trial. The trial court denied both of these motions.
The plaintiff appealed to the Appellate Court, claiming that: (1) the trial court should not have given the jury an instruction on the issue of mitigation of damages because the evidence did not support such an instruction; and (2) if the evidence did support giving such an instruction, the instruction given by the trial [14]*14court on that issue was defective. The Appellate Court rejected the plaintiffs first claim of error, but set aside the judgment as to the amount of damages and ordered a new trial on that issue because it concluded that the trial court’s charge on mitigation of damages was improper in two respects: (1) the court gave only a general charge on the plaintiff’s duty to mitigate damages that did not instruct the jury that the plaintiff’s failure to mitigate must be found to have been the proximate cause of a specific portion of her injuries or of the aggravation of her injuries; and (2) the court did not instruct the jury that the defendant bears the burden of proof on the issue of mitigation of damages.2 Preston v. Keith, 20 Conn. App. 656, 570 A.2d 214 (1990).
We granted the defendant’s petition for certification to appeal, limited to the following two-part question: “In a negligence action in which the evidence raises an issue about the plaintiff’s conduct with respect to the duty to mitigate damages: (1) What instructions should the jury receive about the relationship between mitigation of damages and proximate cause? (2) What is the appropriate allocation of the burden of proof on the issue of mitigation of damages?” Preston v. Keith, 214 Conn. 807, 573 A.2d 320 (1990). We reverse the decision of the Appellate Court on the first part of the question, and affirm its decision on the second part.
The following facts are relevant to this certified appeal. The plaintiff was working as a bus driver on May 15,1985, when the accident that gave rise to this action occurred. On that date, the plaintiff reinjured her lower back, which she had sprained previously in [15]*15an unrelated accident, when the school bus that she was driving was involved in a collision with the defendant’s car. The plaintiffs physical therapy program for her back injury included exercises recommended by her therapist. The Appellate Court found that the record “reflects that the jury had before it abundant evidence from which it could have concluded that the plaintiff did not fully follow her therapist’s directions.” Preston v. Keith, supra, 20 Conn. App. 659.3 The trial court instructed the jury on the issue of mitigation of damages, but its charge did not discuss the relationship between proximate cause and mitigation of damages, nor did it state which party bears the burden of proof on this issue.4
I
We have long adhered to the rule that “one who has been injured by the negligence of another must use reasonable care to promote recovery and prevent any aggravation or increase of the injuries.” Morro v. Brockett, 109 Conn. 87, 92, 145 A. 659 (1929); Sette v. Dakis, 133 Conn. 55, 60, 48 A.2d 271 (1946); Lange v. [16]*16Hoyt, 114 Conn. 590, 595, 159 A. 575 (1932). It is also settled law that when, as in this case, there “are facts in evidence which indicate that a plaintiff may have failed to promote [her] recovery and do what a reasonably prudent person would be expected to do under the same circumstances, the court, when requested to do so, is obliged to charge on the duty to mitigate damages.” Jancura v.Szwed, 176 Conn. 285, 288, 407 A.2d 961 (1978).
In Morro v. Brockett, supra, this court discussed the relationship between mitigation of damages and proximate cause. “The burden is on the plaintiff to establish that the injuries for which he seeks damages were the proximate result of the negligence of the defendant, but when a prima facie case had been made out, as in this instance, it becomes incumbent upon the defendant if he seeks to exonerate himself from responsibility for a portion of the consequences to show that some of these had their proximate cause in the failure of the plaintiff to act in good faith in an attempt to promote recovery and avoid aggravation of the initial injury.” Id., 93-94. Morro established that the theoretical foundation for the plaintiffs duty to mitigate damages5 is that the defendant’s negligence is not the proximate, or legal, cause of any damages that could have been avoided had the plaintiff taken reasonable steps to promote recovery and avoid aggravating the original injury. Morro did not address, however, [17]*17whether a jury must be instructed specifically on the relationship between mitigation of damages and proximate cause in a case where the evidence is sufficient to warrant a charge on mitigation, and it is to that question that we now turn.
“[T]he test of a court’s charge ‘is not whether it is as accurate upon legal principles as the opinions of a court of last resort but whether it fairly presents the case to the jury in such a way that injustice is not done to either party under the established rules of law.’ Atlantic Richfield Co. v. Canaan Oil Co., 202 Conn. 234, 240, 520 A.2d 1008 (1987); Borsoi v. Sparico, 141 Conn. 366, 371, 106 A.2d 170 (1954).” Holbrook v. Casazza, 204 Conn. 336, 351-52, 528 A.2d 774 (1987), cert. denied, 484 U.S. 1006, 108 S. Ct. 699, 98 L. Ed. 2d 651 (1988). “Jury instructions need ‘not be exhaustive, perfect or technically accurate,’ so long as they are ‘correct in law, adapted to the issues and sufficient for the guidance of the jury.’ Castaldo v. D’Eramo, 140 Conn. 88, 94, 98 A.2d 664 (1953) . . . .” State v. Mason, 186 Conn. 574, 585, 442 A.2d 1335 (1982). Applying these standards to the trial court’s instruction on mitigation of damages, we conclude that the court’s charge was proper.
Our conclusion is supported by those authorities that have recognized that instructing a jury on the relationship between mitigation of damages and proximate cause could promote needless confusion. See Beatty v. Davis, 224 Neb. 663, 669, 400 N.W.2d 850 (1987), citing J. Stein, Damages and Recovery: Personal Injury and Death Actions (1972) § 126, p. 220; see also 22 Am. Jur. 2d, Damages § 496.
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Callahan, J.
The issue presented in this appeal is whether the trial court properly instructed the jury on the doctrine of mitigation of damages. The named plaintiff, Rebecca Preston, brought this action to recover for personal injuries arising from an automobile accident allegedly caused by the negligence of the named defendant, Anthony J. Keith.1 Finding that the plaintiff was 50 percent contributorily negligent, the jury returned a verdict for her in the amount of $5593.50. The plaintiff thereafter filed a motion for additur and a motion to set aside the verdict and for a new trial. The trial court denied both of these motions.
The plaintiff appealed to the Appellate Court, claiming that: (1) the trial court should not have given the jury an instruction on the issue of mitigation of damages because the evidence did not support such an instruction; and (2) if the evidence did support giving such an instruction, the instruction given by the trial [14]*14court on that issue was defective. The Appellate Court rejected the plaintiffs first claim of error, but set aside the judgment as to the amount of damages and ordered a new trial on that issue because it concluded that the trial court’s charge on mitigation of damages was improper in two respects: (1) the court gave only a general charge on the plaintiff’s duty to mitigate damages that did not instruct the jury that the plaintiff’s failure to mitigate must be found to have been the proximate cause of a specific portion of her injuries or of the aggravation of her injuries; and (2) the court did not instruct the jury that the defendant bears the burden of proof on the issue of mitigation of damages.2 Preston v. Keith, 20 Conn. App. 656, 570 A.2d 214 (1990).
We granted the defendant’s petition for certification to appeal, limited to the following two-part question: “In a negligence action in which the evidence raises an issue about the plaintiff’s conduct with respect to the duty to mitigate damages: (1) What instructions should the jury receive about the relationship between mitigation of damages and proximate cause? (2) What is the appropriate allocation of the burden of proof on the issue of mitigation of damages?” Preston v. Keith, 214 Conn. 807, 573 A.2d 320 (1990). We reverse the decision of the Appellate Court on the first part of the question, and affirm its decision on the second part.
The following facts are relevant to this certified appeal. The plaintiff was working as a bus driver on May 15,1985, when the accident that gave rise to this action occurred. On that date, the plaintiff reinjured her lower back, which she had sprained previously in [15]*15an unrelated accident, when the school bus that she was driving was involved in a collision with the defendant’s car. The plaintiffs physical therapy program for her back injury included exercises recommended by her therapist. The Appellate Court found that the record “reflects that the jury had before it abundant evidence from which it could have concluded that the plaintiff did not fully follow her therapist’s directions.” Preston v. Keith, supra, 20 Conn. App. 659.3 The trial court instructed the jury on the issue of mitigation of damages, but its charge did not discuss the relationship between proximate cause and mitigation of damages, nor did it state which party bears the burden of proof on this issue.4
I
We have long adhered to the rule that “one who has been injured by the negligence of another must use reasonable care to promote recovery and prevent any aggravation or increase of the injuries.” Morro v. Brockett, 109 Conn. 87, 92, 145 A. 659 (1929); Sette v. Dakis, 133 Conn. 55, 60, 48 A.2d 271 (1946); Lange v. [16]*16Hoyt, 114 Conn. 590, 595, 159 A. 575 (1932). It is also settled law that when, as in this case, there “are facts in evidence which indicate that a plaintiff may have failed to promote [her] recovery and do what a reasonably prudent person would be expected to do under the same circumstances, the court, when requested to do so, is obliged to charge on the duty to mitigate damages.” Jancura v.Szwed, 176 Conn. 285, 288, 407 A.2d 961 (1978).
In Morro v. Brockett, supra, this court discussed the relationship between mitigation of damages and proximate cause. “The burden is on the plaintiff to establish that the injuries for which he seeks damages were the proximate result of the negligence of the defendant, but when a prima facie case had been made out, as in this instance, it becomes incumbent upon the defendant if he seeks to exonerate himself from responsibility for a portion of the consequences to show that some of these had their proximate cause in the failure of the plaintiff to act in good faith in an attempt to promote recovery and avoid aggravation of the initial injury.” Id., 93-94. Morro established that the theoretical foundation for the plaintiffs duty to mitigate damages5 is that the defendant’s negligence is not the proximate, or legal, cause of any damages that could have been avoided had the plaintiff taken reasonable steps to promote recovery and avoid aggravating the original injury. Morro did not address, however, [17]*17whether a jury must be instructed specifically on the relationship between mitigation of damages and proximate cause in a case where the evidence is sufficient to warrant a charge on mitigation, and it is to that question that we now turn.
“[T]he test of a court’s charge ‘is not whether it is as accurate upon legal principles as the opinions of a court of last resort but whether it fairly presents the case to the jury in such a way that injustice is not done to either party under the established rules of law.’ Atlantic Richfield Co. v. Canaan Oil Co., 202 Conn. 234, 240, 520 A.2d 1008 (1987); Borsoi v. Sparico, 141 Conn. 366, 371, 106 A.2d 170 (1954).” Holbrook v. Casazza, 204 Conn. 336, 351-52, 528 A.2d 774 (1987), cert. denied, 484 U.S. 1006, 108 S. Ct. 699, 98 L. Ed. 2d 651 (1988). “Jury instructions need ‘not be exhaustive, perfect or technically accurate,’ so long as they are ‘correct in law, adapted to the issues and sufficient for the guidance of the jury.’ Castaldo v. D’Eramo, 140 Conn. 88, 94, 98 A.2d 664 (1953) . . . .” State v. Mason, 186 Conn. 574, 585, 442 A.2d 1335 (1982). Applying these standards to the trial court’s instruction on mitigation of damages, we conclude that the court’s charge was proper.
Our conclusion is supported by those authorities that have recognized that instructing a jury on the relationship between mitigation of damages and proximate cause could promote needless confusion. See Beatty v. Davis, 224 Neb. 663, 669, 400 N.W.2d 850 (1987), citing J. Stein, Damages and Recovery: Personal Injury and Death Actions (1972) § 126, p. 220; see also 22 Am. Jur. 2d, Damages § 496. “The assertion that the negligence or other tort of the defendant is not the ‘proximate’ cause of the damages which could have been avoided can be accepted as theoretically valid since proximate cause really means that cause which is recognized by the law as the cause of the damages. Stated [18]*18in such terms, the concept has the doubtful virtue of imprecision. If a jury is instructed, for example, that if the defendant’s negligent activity caused the plaintiff’s broken leg and caused some pain; but that much of the pain could have been avoided had the plaintiff consulted a doctor; and that the jury must compensate the plaintiff for that pain which, in natural and continuous sequence, unbroken by any efficient intervening cause, flowed from the act of the defendant; it is reasonable to assume that the jury is going to be confused. It is much more precise and clear to state that the plaintiff could have avoided some of the pain by going to a doctor and that, as a matter of policy, he cannot recover for the pain which could have been avoided.” J. Stein, supra, § 126, p. 220.
Our conclusion that a jury need not specifically be instructed on the relationship between proximate cause and mitigation of damages does not, as the plaintiff suggests, mean that we are overruling Morro v. Brockett, supra,6 or that we are discarding settled principles of the doctrine of mitigation. Nor do we hold that it would be error to instruct the jury on the relationship between [19]*19proximate cause and mitigation of damages, where this instruction is stated in terms that would not confuse a reasonable juror. It is axiomatic that a charge on mitigation of damages must provide some indication to a jury that it should apply this doctrine only if a plaintiffs alleged failure to mitigate is found to have caused the aggravation of the injury. We conclude that the trial court’s instruction in this case that “y°u should reduce any award you might give her to such a sum as you think measures the amounts which her damages have been increased by her failure ... to mitigate damages” sufficiently conveyed this notion of causation.
II
A second reason relied upon by the Appellate Court in determining that the trial court’s charge was defective was that the charge did not include any discussion of the burden of proof on the issue of mitigation of damages.7 Preston v. Keith, supra, 20 Conn. App. 663. The Appellate Court concluded that in a negligence case the defendant bears the burden of proof, i.e., the burden of persuasion, on the issue of mitigation of damages and that the jury should have been so instructed. Id., 663-64. The defendant argues that a defendant in a negligence action bears the burden of production [20]*20but not the burden of persuasion on mitigation.8 We affirm the decision of the Appellate Court on this issue.
As a general rule, the burden of proving damages lies with the plaintiff. Milgrim v. Deluca, 195 Conn. 191, 199, 487 A.2d 522 (1985); Miner v. McKay, 145 Conn. 622, 624, 145 A.2d 758 (1958). “Damages are an essential element of a plaintiff’s proof and must be proved with reasonable certainty.” Simone Corporation v. Connecticut Light & Power Co., 187 Conn. 487, 495, 446 A.2d 1071 (1982); Bianco v. Floatex, Inc., 145 Conn. 523, 525, 144 A.2d 310 (1958). The plaintiff must also prove that the defendant’s alleged negligence was the proximate cause of his or her damages. Coburn v. Lenox Homes, Inc., 186 Conn. 370, 372, 441 A.2d 620 (1982). These general principles, however, do not address the question of who bears the burden of proof on the issue of mitigation of damages in a negligence case.
Although this court has never addressed this precise question,9 a review of the relevant authorities reveals [21]*21that “[t]he burden of proving that the injured party could have avoided some or all of his or her damages universally rests on the party accused of the tortious act.” 2 M. Minzer, Damages in Tort Actions (1989) § 16.11, p. 16-18; see, e.g., Jones v. Consolidated Rail Corporation, 800 F.2d 590, 593 (6th Cir. 1986) (applying federal law); Harris Construction Co. v. Powers, 262 Ark. 96, 105, 554 S.W.2d 332 (1977); Slater v. Chicago Transit Authority, 5 Ill. App. 2d 181, 185, 125 N.E.2d 289 (1955);Michaud v. Steckino, 390 A.2d 524, 531 (Me. 1978); Williams v. Masters, Mates & Pilots of America, Local No. 2, 384 Pa. 413, 422, 120 A.2d 896 (1956); F. Harper, F. James & O. Gray, Torts (2d Ed.) § 20.3, p. 127; C. McCormick, Handbook on the Law of Damages (1935) § 34, p. 130; J. Stein, supra, § 130, p. 226. The rule placing the burden of proof on the issue of mitigation of damages upon the defend[22]*22ant applies to actions for personal injuries or property-damage arising out of tortious activity and to actions for breach of contract.10 J. Stein, supra. The defendant is unable to cite any authority, and our research has revealed none, to support his claim that in a negligence action the defendant bears the burden of production, but not the burden of persuasion, on the issue of mitigation of damages.
The rationale for this rule is well established. A defendant claiming that the plaintiff has failed to mitigate damages “ ‘seeks to be benefited by a particular matter of fact, and he should, therefore, prove the matter alleged by him. The rule requires him to prove an affirmative fact, whereas the opposite rule would call upon the plaintiff to prove a negative, and therefore the proof should come from the defendant. He is the wrongdoer, and presumptions between him and the person wronged should be made in favor of the latter. For this reason, therefore, the onus must in all such cases be upon the defendant.’ ” 1 T. Sedgwick, Damages (9th Ed. 1912) § 227, p. 448.
To claim successfully that the plaintiff failed to mitigate damages, the defendant “must show that the injured party failed to take reasonable action to lessen the damages; that the damages were in fact enhanced by such failure; and that the damages which could have been avoided can be measured with reasonable certainty.” 2 M. Minzer, supra, § 16.10, p. 16-18.
The defendant argues that placing the burden of persuasion on the issue of mitigation upon the defendant [23]*23in a negligence action will result in a “trial within a trial” by forcing the defendant to call expert witnesses in order to satisfy the burden of persuasion. Although it would certainly seem advisable for a defendant raising a claim that the plaintiff failed to mitigate damages to present his own witnesses on this issue; see 2 M. Minzer, supra, § 16.11, p. 16-20; we do not believe that a defendant could never satisfy his burden of persuasion solely through the cross-examination of the plaintiff and the plaintiffs witnesses. Furthermore, requiring the defendant to prove that a plaintiff has failed to mitigate damages places no greater a burden on the judicial system than does General Statutes § 52-114,11 which requires a defendant pleading contributory negligence to bear the burden of persuasion on this issue.
The judgment of the Appellate Court is reversed in part and affirmed in part,12 and the case is remanded to that court with direction to remand the case to the [24]*24trial court with direction to set aside the judgment only as to the amount of damages awarded and to order a new trial limited to that issue.
In this opinion the other justices concurred.