An appellate court exercising inherent jurisdiction to unravel the consequences of orders set aside on appeal may order repayment of overpaid damages with interest, but unsatisfied costs orders in favour of the respondent should be deducted from the overpayment before interest is calculated. The rate of interest on such overpayments is discretionary and not governed by statutory provisions applicable to other contexts, but fairness may require the same rate as applied to the original judgment.
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