Salton and Morand (No 2)

In *Salton and Morand (No 2)*, the applicant sought an order that the respondent pay the costs of family law proceedings. The respondent had not participated in the substantive proceedings, and orders had been made as sought by the applicant. The applicant's costs were described as modest.

The central legal issue before Rees J was whether the respondent's failure to engage in the proceedings, in itself, justified an order for the respondent to pay the applicant's costs.

Rees J reasoned that a party's non-participation in proceedings, without more, is not a sufficient ground to depart from the usual rule that each party bears their own costs. The court found that the respondent's lack of engagement did not, on its own, warrant ordering the respondent to pay the applicant's costs.

Consequently, the application for costs was dismissed.