What is the test for an appeal against an award of costs in a personal injury case?

Trial judges have a broad discretion in awarding costs. An appellate court may only interfere with an award of costs if it can be demonstrated that “the trial judge has made an error in principle or if the costs award is plainly wrong”: Hamilton v. Open Window Bakery Ltd., 2004 SCC 9 at para. 27.

I turn first to the award for special costs for 10 days of the trial. Special costs are typically awarded when there has been some form of reprehensible conduct by a party which the court determines should be subject to rebuke: Young v. Young, 1993 CanLII 34 (SCC), [1993] 4 S.C.R. 3 at 134. While special costs are usually awarded for the whole of a proceeding, it is open to a judge to make a partial award of special costs if he or she is of the view that it would be disproportionate to award special costs for the entire proceeding: Gichuru v. Smith, 2014 BCCA 414 at para. 91.