Is there an entitlement to costs for self-represented litigants who are not legally trained?
Ontario, Canada
The following excerpt is from Proulx v. Viau, 2009 ONCJ 159 (CanLII):
[21] In Fong v. Chan, the court was considering an award of costs for self-represented litigants but the elements of such costs concerned the work of lawyers, either salaried, partners or retained counsel. I do not read the cases of Fong v. Chan or Brazeau v. Lefebvre as establishing a ready entitlement to costs for self-represented litigants. Indeed, the case of Fong v. Chan did not involve a claim by a litigant who was not legally trained. The court did offer passing comment on the entitlement to costs claimed by a litigant, legally trained or not, as follows:
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