In what circumstances have courts awarded special costs in family law cases where a party deliberately misled the court about income and marital assets?

In family law cases, courts have awarded special costs in situations where a party has deliberately misled the court through repeated failure to disclose income or marital assets, or repeated non-disclosure of other information despite court orders. In Bains v. Bains, 2006 BCSC 1187, Justice Gropper awarded special costs where the defendant, inter alia, attempted to mislead the court at trial regarding his income, refused to swear an oath upon giving testimony, disobeyed court orders, and refused to answer questions under oath on examination for discovery.