The threshold of wrongdoing that is required for an award of costs on a solicitor and client basis is very high. McLachlin J., as she then was, in Young v. Young, 1993 CanLII 34 (SCC), [1993] 4 S.C.R. 3, 108 D.L.R. (4th) 193 described the kind of conduct that warrants this kind of award: Solicitor‑client costs are generally awarded only where there has been reprehensible, scandalous or outrageous conduct on the part of one of the parties.
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