In my view, the conduct of the husband deserves the rebuke of a special costs order, particularly as it is in a family law proceedings in which the legal costs incurred by the wife are attributable to the husband’s reprehensible conduct. Similar to Holmes v. Matkovich, 2007 YKSC 5 (aff’d 2008 YKCA 10), the husband has failed to fully disclose his income and failed to produce his business income or provide an evaluation of the value of his construction business. Failure to disclose, particularly in family law proceedings, strikes at the heart of the civil justice system.
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