What is the test for using a jointly appointed expert in a family matter?

Rule 13-3 reflects a “strong policy preference” for the use of joint experts on financial issues in family cases (Aquilini v. Aquilini, 2012 BCSC 1616 at para. 10). Common features of family cases including the central importance of the division of family assets, the cost of expert evidence, unequal distribution of financial resources to pay for an expert, the likelihood of substantial agreement between experts, and the sometimes overly adversarial nature of family cases warrant such a rule (Aquilini at para. 10). The decision to limit evidence by use of a joint expert is unique to family cases (Aquilini at para. 10), but a limitation on the number of experts allowed has most recently been applied to litigation of damages arising from personal injury or death in motor vehicle cases (Rule 11-8 Supreme Court Civil Rules, O.C. 040, February 11, 2019). The preference for a jointly appointed expert in a family case is stated in mandatory terms such that exercise of the court discretion in Rule 13‑3(2)(a) should not relieve a party of the requirement unless use of a joint expert is “inappropriate or impracticable” (Aquilini at para. 35).