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Of course, not every case demands a summary assessment of costs. There will be
interlocutory applications where the appropriate order would be for the costs to be "in
the cause" or "in any event" or "reserved". In other cases, the costs may be substantial
and complex, making them unsuitable for final assessment summarily. And as
discussed below, it may in some cases be appropriate to undertake a provisional
summary assessment, ordering the assessed costs to be paid promptly while reserving
to any party who feels aggrieved by the amount summarily assessed the right to seek a
taxation and an adjustment of the sum payable or receivable at the end of the
proceedings.
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