Whelan and Whelan (No. 2)

In *Whelan and Whelan (No. 2)*, the wife sought costs in relation to proceedings that had concluded prior to the filing of her application. The matter came before Watts J.

The central legal issue before the court was whether the wife's application for costs, filed significantly after the substantive proceedings had been resolved, could be entertained. The court was required to consider the timeliness of such applications and the principles governing the award of costs in family law matters.

Watts J dismissed the wife's application, finding that it was made out of time. The court applied the principle that costs applications should generally be brought promptly following the determination of the substantive issues. The delay in this instance was considered unreasonable, and therefore, the wife was not entitled to pursue her claim for costs at that late stage.