What is the test for making a cost award in a personal injury case?

Obviously, the discretion must be exercised judicially, which is to say not arbitrarily or capriciously. While the trial judge is not required to itemize in detail the many factors that may have been taken into account in making a costs award, appellate intervention may be required where the reasons do not reveal the foundation upon which the trial judge exercised his or her discretion: White v. Nuraney, 2000 BCCA 675 at para. 10.

The high standard of review established in relation to a costs award applies equally to an award of special costs: Ahousaht Indian Band and Nation v. Canada (Attorney General), 2011 BCCA 425 at paras. 17–18.