As a result, case law pertaining to costs decided under the Rules of Civil Procedure should be approached with some caution. For example, in Beaver v. Hill, 2018 ONCA 840 at paras. 9-11, Nordheimer J.A. noted that there is no provision in the Family Law Rules that provides for a general approach of “close to full recovery” costs. Rather Rule 24(12) outlines appropriate considerations in fixing the quantum of costs.
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