What is the current state of the law on personal costs against a solicitor?

Ontario, Canada


The following excerpt is from Carleton v. Beaverton Hotel, 2009 CanLII 92124 (ON SCDC):

I agree with the appellant's submission that the "extreme caution" which courts must exercise in awarding costs against a solicitor personally as stated in Young v. Young, means that these awards must only be made sparingly, with care and discretion, only in clear cases and not simply because the conduct of a solicitor may appear to fall within the circumstances described in rule 57.07(1).

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