What is the test for the purpose of special costs in family matters?

British Columbia, Canada


The following excerpt is from M.P. v. N.M., 2009 BCSC 40 (CanLII):

In family matters, the failure to disclose important financial information and deliberately misleading the court is “deserving of the rebuke of special costs”: Rozen v. Rozen, 2002 BCCA 537, 173 B.C.A.C. 102.

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