Commercial Copy Rates Not Helpful When Addressing Reasonable Photocopy Disbursements
A decision was recently publshed by the BC Supreme Court website addressing reasonable photocopy disbursements in an ICBC Claim. Although it is a 2006 decision decided under the old rules, the Court’s comments remain relevant finding that commercial photocopy charges are not helpful when deciding a reasonable rate to charge for photocopy disbursements due to litigant privacy concerns.
In the recently published case (Kind v. Leung) Master Caldwell provided the following observation:
5] There is also information in here about photocopying through commercial endeavours. There are privacy concerns related there and I take counsel’s point, but again the physical cost of copying in those facilities seems to run between five cents and 10 or 11 cents per page.
 Making allowance for in-house copying at a reasonable rate to meet the obligations of privacy and confidentiality, given the costs as I seem to have limited information here in the material relating to equipment, I am not able to indicate or to determine on the material provided by the plaintiff that their costs exceed 30 cents a page. The rate set will be 30 cents per page.
You can click here to access more recent caselaw addressing photocopy disbursements.