Narejko v Li

Decided: 2026-09-24. Docket: CA50147. Citation: 2026 BCCA 393 (CanLII). Procedure — Costs — Special costs assessment — Court of Appeal Rules, Rule 71 — Fees and disbursements “properly or reasonably necessary to conduct the proceeding” — Complexity and time reasonably spent assessed — Reductions for excessive hours and “library searches” as overhead — Special costs assessed | Procedure — Costs — Pro bono representation — Special costs despite pro bono services — Whether pro bono services preclude recovery of special costs — Authorities applied including Tanious v The Empire Life Insurance Company and Arbabi v McLelland — No requirement to assure payment to counsel — Special costs allowed | Procedure — Costs — Proceedings in aid of assessment — Recovery of special costs for assessment-relat