“Historically in Ontario the courts have generally not imposed full recovery of costs (“solicitor-client costs”) unless the party liable for costs has behaved in such a manner as to deserve to be punished. The avoidance of the term “solicitor-client costs” probably signals a desire to leave the law surrounding that approach behind. I agree with Aston J. in Sims‑Howarth v. Bilcliffe, 2000 CanLII 22584 (ON SC), [2000] O.J. No. 330 (Ont. S.C.J.), citing Mallory v. Mallory (1998), 35 R.F.L. (4th) 222 (Ont. Gen. Div.), that the preferable approach in family law cases is to have costs recovery generally approach full recovery, so long as the successful party has behaved reasonably and the costs claimed are proportional to the issues and the result. There remains, I believe, a discretion under r. 24 (1) to award the amount of costs that appears just in all the circumstances, while giving effect to the rules’ preeminent presumption, and subject always to the rules that require full recovery or that require or suggest a reduction or an apportionment. This is not to say that the discretion extends to awarding just $1 to a successful, reasonable party. That would be not to give a reasonable interpretation to the presumption in r. 24 (1) that “a successful party is entitled to the costs” [bold face added] of a motion, etc. A $1 or even a $500 award on account of the $2,000 costs properly and reasonably expended on a motion would not appear to me to be respectful of the rule.”