What is the test for disbursement in a personal injury action?

British Columbia, Canada


The following excerpt is from 567 Hornby Apartment Ltd. v. Le Soleil Hospitality Inc., 2016 BCSC 1340 (CanLII):

A disbursement must be allowed if, at the time the disbursement was incurred, it was necessary and proper. A “necessary” disbursement is one that is essential to the conduct of the action. A “proper” disbursement is one that, though perhaps not “necessary”, was reasonably incurred for the purposes of the proceeding. [McKenzie v. Darke, 2003 BCSC 138 at paragraph 18].

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