What is the test for solicitor-client costs?

Special costs, or “solicitor-client costs”, are intended to more closely represent a party’s actual legal costs. As to what principles should govern the award of solicitor-client costs, in Young v. Young, 1993 CanLII 34 (SCC), [1993] 4 S.C.R. 3 at 134, McLachlin J. (as she then was) stated the following: … Solicitor-client costs are generally awarded only where there has been reprehensible, scandalous or outrageous conduct on the part of one of the parties. Accordingly, the fact that an application has little merit is no basis for awarding solicitor-client costs; nor is the fact that part of the cost of the litigation may have been paid for by others. [emphasis added]