This case was applied in Brar v. Hall [1990] B.C.J. No. 2505 (S.C.) supp. Reasons (Q.L.), where Coultas J. said: The effective functioning of the court system when dealing with suits arising out of motor vehicle accidents, often placed before juries, depends on matters proceeding as expeditiously as possible. That objective is not assisted by having individual litigants represented by more than one counsel. Accordingly, it is important to limit dual representation of individual parties to those cases where a true divergence of interest can be demonstrated. A party’s choice to be individually represented cannot be denied, but pursuing that course can be made less appealing knowing that in all but a very few circumstances no costs will be allowed should a party pursue it.
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