The court confirmed that the 30-day time limit in O 66 r 51(2) of the Rules of the Supreme Court (WA) for applying for a special costs certificate can be extended under the general power to extend time. A trial judge's own experience of the complexity of a case at trial may be sufficient to establish the basis for a special costs order under O 66 r 12(1), even where the supporting affidavit evidence is thin.
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