In her decision in Browne v. Cerasa, 2018 ONSC 2242, Justice Fryer states as follows: “Determination of costs for self-represented litigants should take into account all of the objectives which costs orders should promote. Rules 18 and 24 apply. Otherwise the resulting amount can render the entitlement to costs illusory; undermine access to justice by self-represented litigants; and frustrate the administration of justice.”
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