Costs awards from interlocutory proceedings are not usually payable forthwith for two reasons: (a) to avoid adverse financial repercussions to the unsuccessful litigant that would prevent it from proceeding with the litigation; and (b) to avoid limiting the range of options available to the trial judge to deal with costs at the conclusion of the litigation: Lalji v. Sunderji,  B.C.J. No 239 (S.C.).
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