As will be observed, excepting Skidmore v. Blackmore, supra, the authorities relied on by the Attorney were decided outside of British Columbia. These authorities provide that a self-represented litigant may receive an award of costs, including what are described as daily “counsel fees”, but: a. those costs should not include compensation for time and effort which would have been expended in any event as a litigant in the proceeding; and b. the litigant must demonstrate an “opportunity cost”. That is, the litigant must show that he or she was required to forego remunerative work in order to appear in the proceeding.
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