When can a self-represented litigant claim costs?
Ontario, Canada
The following excerpt is from Langenfeld v TPSB, 2018 ONSC 5309 (CanLII):
The Court of Appeal in Fong v. Chan stated the following two-part test for when costs (apart from disbursements) may be awarded to a self-represented litigant: “Costs should only be awarded to those lay litigants who can demonstrate that they devoted time and effort to do the work ordinarily done by a lawyer retained to conduct litigation and that, as a result, they incurred an opportunity cost by forgoing remunerative activity.” (Paragraph 26)
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