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ARTICLE · 04 AUGUST 2025

Security For Costs Do Not Come Easy: A Lesson From Bains v Adam 2025 ABCA 235

CLC (Canadian Litigation Counsel)
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In Bains v Adam, 2023 ABKB 491, Dr. Jagdev Singh Bains brought three actions against the various named defendants, relating to three separate motor vehicle accidents that occurred in 2017.

CanadaLitigation, Mediation & Arbitration
Inderpal Gill (Brownlee Law)
Inderpal Gill (Brownlee Law)

In Bains v Adam, 2023 ABKB 491, Dr. Jagdev Singh Bains brought three actions against the various named defendants, relating to three separate motor vehicle accidents that occurred in 2017. These actions were tried together and were ultimately dismissed – the Court found Dr. Bains was not entitled to damages and ordered him to pay over $440,000 in costs to the defendants.


Dr. Bains then went through a series of attempted appeals of that decision, at the ABCA, including an unsuccessful appeal of the aforementioned substantial costs award against him - that history is available here, at paragraphs 3 and 4. These appeals ultimately culminated in the defendant Applicants bringing a security for costs application against Dr. Bains on January 29, 2025, which is the subject of this case comment: Bains v Adam 2025 ABCA 235.

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