Rule 15 of the British Columbia Supreme Court Civil Rules pertains to “fast track” litigation, which is meant to apply to cases worth less than $100,000, or cases where the trial duration would be less than three days. The Court can also order that the matter proceed via the fast track route, or the parties can consent to it.
In Wang v. Dhaliwal, the Plaintiff was injured in two motor vehicle collisions, and brought ICBC claims for damages for pain and suffering, as well as various other types of damages. Two separate legal actions were commenced by the Plaintiff. Both cases were eventually settled prior to trial on a global basis, however the parties could not agree on a proper costs award, necessitating a costs assessment before the District Registrar. Counsel for the Plaintiff argued that two sets of costs should be awarded, however ICBC’S lawyer argued that only one set was appropriate. It would eventually be ruled that two sets of costs would be awarded.
 Although the two actions were ordered to be tried together, by consent, they involved different defendants and the issues were not identical: liability had been denied in the December 15, 2010 action and an allegation of contributory negligence had been raised by the defendant in the June 14, 2011 action. Further, the defendants required two examinations for discovery of the plaintiff in the two separate actions and the plaintiff had to conduct an examination for discovery of each defendant in the two actions.
 The only commonality in the two actions was the fact that they involved injuries to the same plaintiff. In the circumstances, it was appropriate to bring two separate legal actions involving the different defendants and circumstances. It was equally appropriate to eventually join the cases for the purposes of trial once it became apparent this approach was workable and efficiencies would be achieved.