What is the current state of the law on indemnity costs for perjury?

Third, Brown v. Roque, supra, has rarely been followed. [See Note 7 below] On the other hand, there are numerous cases where dishonesty on the part of one of the parties either alone, [See Note 8 below] or in combination with other factors, [See Note 9 below] has resulted in an award of substantial indemnity costs. I prefer these latter authorities, as there are few types of conduct engaged in by litigants that are more deserving of judicial disapprobation than perjury or knowingly leading false evidence. Such behaviour increases the costs incurred by the innocent party, dissipates the resources of the court, undermines the integrity of the trial process and can perilously complicate the search for justice. The costs sanction is one of the few ways a court can signal its disapproval of such [page392] conduct and make it clear to other litigants that such behaviour will not be condoned.