However, even if this is true, it is not clear that costs awards are a fair or effective way to deal with vexatious self - represented inmates on
unsuccessful habeas corpus applications because the rules of costs contemplate represented litigants, not self - represented ones.
However, it is important to note that Justice Crighton's decision did not only follow the Alberta Rules of Court, but also relied on Alberta precedent for awarding costs against an
unsuccessful self - represented
habeas corpus applicant.