The same result obtained in Odhavji Estate v. Woodhouse, 2003 SCC 69, where the court recognized two types of public interest litigants (at ¶76): (i) litigants who have no direct pecuniary or other material interest in the proceedings (e.g. a non-profit organization); and (ii) litigants who do have a pecuniary interest, but whose interest is modest in comparison to the cost of the proceedings.
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