The proportionate costs 'rule of thumb' from Currabubula Holdings (which limits each defendant's share of costs where a plaintiff succeeds against some defendants but fails against others) does not apply where the plaintiff succeeds against all defendants sued to judgment. In such cases, the usual order of joint and several liability for costs applies. A successful plaintiff's failure on a factual sub-issue (here, election) does not justify departure from the general rule that costs follow the event where there was a reasonable basis for raising the issue.
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