The adequacy of a magistrate's reasons for a costs order in a minor case under s 31(3)(a) of the Magistrates Court (Civil Proceedings) Act 2004 (WA) must be assessed in the context of the informal and expeditious nature of the minor cases procedure, the limited right of appeal, and the summary nature of the Magistrates Court. A magistrate's identification of the facts relied upon in combination as constituting exceptional circumstances, together with identification of the applicable statutory test, will satisfy the duty to give reasons even without express articulation of why those facts are exceptional. The question whether inadequate reasons can constitute a denial of natural justice for the purpose of s 32(3)(b) was raised but left open.
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