Is there any case law supporting a wife’s position in seeking costs in matrimonial litigation?

[9] Weir v. Weir (No. 2) also appears to be some support for the traditional notion that matrimonial litigation is different with regard to costs and, specifically, that a wife’s position in seeking costs may be treated more favourably than other parties in civil litigation.

[10] But Berdette v. Berdette, supra, seems to move again in favour of there being no distinction between matrimonial litigation and other civil litigation. These decisions are not inconsistent in so far as they both suggest that it is imperative that, to get an order for costs in matrimonial litigation, the party seeking costs must have made a reasonable offer. This is part of a sensible policy of encouraging settlement and discouraging unnecessary litigation by punishing the unreasonable spouse.