Is a plaintiff entitled to double costs under Rule 37 of the Rules of Civil Procedure if it makes a single offer to settle two separate actions?

In Starling v. Martin, [1996] B.C.J. No. 2486 (S.C.) (Q.L.) a plaintiff had made a single offer to settle two actions and at trial was awarded total damages in excess of that offer. The defendants argued that the plaintiff was not entitled to double costs under Rule 37 because the offer proposed a global settlement and did not specify separate amounts for each action. Dillon J. allowed double costs and said at para. 7: Here the actions were ordered to be tried together and, in that sense, became a single proceeding. Any ambiguity in the terms of the offer related only to the differentiation of amounts in the two actions. The rule should not be interpreted so strictly as to require two offers to settle to be made when actions are to be tried together and the damages are so intertwined that a single settlement offer is appropriate. If the receiver of the offer required differentiation of settlement amounts in the two actions, it should have requested clarification of the settlement in that regard.