A self-represented litigant who succeeds on appeal is entitled to a costs order in their favour at trial, but recoverable costs are limited to disbursements and witness expenses. An opposing party's untenable legal arguments at trial do not necessarily warrant departure from the general costs rule, particularly where the successful party was unrepresented (and thus cannot recover professional costs for time spent on those arguments) and where the absence of a costs order on a cross-claim provides an effective set-off.
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