Presentation - Costs. Zbogar v. Dhall
In Zbogar v. Dhall (Div Ct, 2020) the Divisional Court set out the test for cost awards for presenting parties:
 Fong v. Chan, 1999 CanLII 2052 (ON CA), provides that that costs should only be awarded to a self-represented litigant who can demonstrate that they devoted time and effort to do the work ordinarily done by a lawyer retained to conduct the litigation and that the work done by them resulted in a loss by forgoing remunerative activity. The Divisional Court in Mustang Investigations v. Ironside 2010 ONSC 3444 confirmed that Fong remains good law.. Di Geso v. Pascoe
In Di Geso v. Pascoe (Div Ct, 2022) the Divisional Court extensively considered costs awarded to presenting parties.