1A self-represented litigant's status as legally trained (holding a doctoral law qualification and prior admission to practice) may diminish the weight given to self-representation as a factor militating against adverse or indemnity costs orders.
2An unreasonable failure to accept a Calderbank offer may justify indemnity costs, but the court retains discretion to fix the indemnity period by reference to when the offeree's continued prosecution of the proceeding became unreasonable, rather than from the date the offer lapsed.
3The public interest character of underlying substantive claims does not necessarily extend to interlocutory or procedural appeals, and Oshlack principles have limited application where the proceeding concerns leave to appeal out of time from discretionary case management orders.
