What are the guiding factors for awarding personal costs against counsel personally?

Ontario, Canada


The following excerpt is from Falcon Lumber Limited v. 2480375 Ontario Inc. (GN Mouldings and Doors), 2020 ONCA 310 (CanLII):

The motion judge properly instructed himself on the law concerning awards of costs against counsel personally. He understood that such awards are rare and he accurately summarized the guiding factors as discussed in Galganov v. Russell (Township), 2012 ONCA 410, 294 O.A.C. 13.

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