What are necessary and proper disbursements?
British Columbia, Canada
The following excerpt is from Sawyer v. Recuenco, 2013 BCSC 968 (CanLII):
In Zaenker v. Kirk, 2008 BCSC 1460, the court noted at paragraph 24: …. “necessary” disbursements are essential disbursements, which means that they are outlays that could not be avoided in the conduct of the proceeding, whereas “proper” disbursements are those reasonably incurred in the conduct of the proceeding but are, strictly speaking, avoidable.
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