What are the implications of a personal costs order against counsel personally?
Canada (Federal), Canada
The following excerpt is from Zaldin v. Canada, 2000 CanLII 15621 (FCA):
An award of costs payable by counsel personally is an extraordinary order. Such orders are made sparingly and only in clear cases (see Myers v. Elman, [1940] A.C. 282). As we have indicated, there was much confusion in this case. In the circumstances, an award of costs against counsel personally would be inappropriate.
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