For example, in Pitts v. O'Dwyer (1892), 7 Nfld. L.R. 675 (S.C. en banc), where the plaintiff succeeded on one cause of action but failed on two others, the court recognized that costs could be awarded and taxed distributively on a per-event basis if each event is distinct in character and could have been the subject of separate suits. In Pitts, where the plaintiff lost on his two major claims of trespass and conversion of a ship but succeeded on a claim for money had and received, two of three judges opted for a distributive result and held that the plaintiff was nevertheless entitled to general costs of the action insofar as they related to producing the result in his favour but that the defendant was entitled to costs associated with his defence of the claims on which he was successful.
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