Such approach displaces the “traditional” approach to costs whereby the costs of a proceeding were generally paid out of the estate subject to certain exceptions as follows: “The practice of the English courts, in estate litigation, is to order the costs of all parties to be paid out of the estate where the litigation arose as a result of the actions of the testator, or those with an interest in the residue of the estate, or where the litigation was reasonably necessary to ensure the proper administration of the estate”. McDougald Estate v. Gooderham, supra
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