Where a cross-claim fails solely because the plaintiff's claim against the defendant fails, the reasonableness of the defendant's joinder of the cross-defendant is a necessary but not sufficient condition for ordering the plaintiff to pay the cross-defendant's costs. Where there is a substantial identity of interests between defendant and cross-defendant, the cross-defendant is expected to co-operate with the defendant to avoid duplication of effort and costs; failure to do so may result in the cross-defendant recovering only a proportion of its costs from the plaintiff. A cross-defendant wishing to have all its costs paid by the plaintiff should demonstrate it followed a reasonable strategy to minimise duplication.
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