The Court of Appeal in Fong v. Chan made it clear that even if self-represented litigants are entitled to costs if they are the successful party in a proceeding, they are not entitled to costs calculated on the same basis as those litigants who retain counsel. The self-represented litigant should not recover costs for the time and effort that any litigant in the case would have devoted to the case. Generally, they must satisfy the court that they have incurred an opportunity cost for doing so.
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