Mansfield v College of Physicians and Surgeons of Newfoundland and Labrador

canada, canadian, case law, court opinion, canlii, nlca, 2026nlca17, 2026 nlca 17 (canlii), 2026, nlca, 17, (canlii), 202501h0042, 2026, procedure, appeals, security for costs, court of appeal civil rules, 2025, rule 43(1), whether “special circumstances” justified security for costs on appeal, discretion under successor to rules of the supreme court, 1986, rule 57.13, application assessed on limited record, security for costs refused, procedure, costs, security for costs evidence, whether applicant/intervenor clearly demonstrated appellant could not pay costs, reliance on non, payment of taxed costs and no registered real property, request to stay costs order or pay into court pending appeal, insufficient proof of insufficient assets, application dismissed, procedure, appeals, apparent merits threshold, whether it is “reasonably or fairly apparent” that the appeal has merit, court mindful of premature view on outcome, preliminary assessment of discretionary intervention and costs orders, good arguments of error in principle identified, merits found sufficient to resist security, procedure, costs, intervenors, whether intervenors are usually not awarded costs, affecting security and disposition, general rule from the law of costs and elton estate v. elton, factors to deviate, including circumstances and extent of participation, applicant/intervenor unsuccessful and ordered to pay costs, costs taxed on column iii