The Court of Appeal held that where a litigant in person is assisted by a McKenzie friend who is not an admitted practitioner, costs are limited to out-of-pocket expenses and do not extend to fees for the McKenzie friend's services quantified as professional legal costs. The grant of leave for a McKenzie friend to present submissions does not place a 'responsibility' on that person equivalent to a legal practitioner's retainer, and the friend cannot recover professional fees from the opposing party.
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