How have costs been apportioned in motor vehicle accident cases?

In Terris v. Crossman, [1995] P.E.I.J. No. 116 Jenkins J., ruling on costs, gave weight to the disproportionality between the damages sought by the plaintiff and the actual damages awarded at trial. In paragraph (3)(ii) he stated: 3(ii) The amount claimed and the amount recovered are disproportionate; and the plaintiff obtained only very limited success on the issues in contention. While she obtained damages relating to the whiplash injury, she was not successful with regards to the main issues at trial...Nominal success on damages alone is not necessarily a basis for denial of costs to a successful plaintiff. But where, as here, there is divided and limited, success on the issues, costs may, depending on the circumstances, be apportioned or denied.