Bullock and Sanderson Orders. Rooney (Litigation Guardian of) v. Graham
In Rooney (Litigation Guardian of) v. Graham (Ont CA, 2001) the Court of Appeal considers Bullock and Sanderson orders:
 A Bullock order directs an unsuccessful defendant to reimburse the plaintiff for the recovered costs of a successful defendant. A Sanderson order directs that the payment go directly to the successful defendant. The [rationale] behind both orders is the same. Where the allocation of responsibility is uncertain, usually because of interwoven facts, it is often reasonable to proceed through trial against more than one defendant. In these cases, a Bullock or Sanderson order provides a plaintiff with an appropriate form of relief.
 A Bullock or Sanderson order has been said to be inappropriate when an independent cause of action is alleged against each defendant, for example when one is based in contract and the other in tort, or when separate actions have been instituted against each defendant. See Scarboro Golf & Country Club Ltd. v. Scarborough (City) (No. 2) (1986), 1986 CanLII 2707 (ON SC), 57 O.R. (2d) 202, 32 D.L.R. (4th) 732 (H.C.J.) and Dellelce Construction & Equipment v. Portec Inc. (1990), 1990 CanLII 6858 (ON SC), 73 O.R. (2d) 396 at p. 442, 44 C.P.C. (2d) 165 (H.C.J.).
 In my view, these authorities do not provide a blanket rule that a Bullock or Sanderson order can never be made when the causes of action are independent, or when separate actions are instituted. Although such circumstances may indicate the appropriateness of these orders, and will at times be determinative, each case must be assessed on its own facts. The proper approach to issuing a Bullock or Sanderson order will consider each case in its context. Thus, there may be times where the causes of action are independent or the actions separate, but it is nevertheless fair that the responsible defendant be called upon to pay for the inclusion of others in the trial proceedings.