What costs consequences follow if a beneficiary's objection to a passing of accounts is found unreasonable?

If a court finds that a beneficiary's objection to a passing of accounts was unreasonable — for example, raised without real evidence, pursued after it was clearly unfounded, or driven by something other than a genuine concern about the accounts — the court has discretion to order that beneficiary to pay costs, potentially including the trustee's costs of responding to the objection.

This is a real financial risk, not just a theoretical one. Estate litigation costs can add up quickly once a matter proceeds to a hearing, and a beneficiary who loses on an unreasonable objection may end up paying out of their own pocket rather than having those costs absorbed by the estate, and therefore effectively shared among all beneficiaries. Courts do distinguish between an objection that turned out to be wrong but was reasonably raised, and one that was clearly unjustified or pursued unreasonably — the latter is what tends to attract a costs order against the objecting party personally.

Given that risk, a beneficiary thinking about objecting to specific entries in an estate trustee's accounts should get a realistic sense, ideally from a lawyer who has reviewed the actual accounts, of how strong the objection is before filing it, rather than objecting reflexively.