Virginia Code § 8.01-521

Judgments as to costs
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Unless the garnishee appear to be liable for more than is so delivered and paid, there shall be no judgment against him for costs. In other cases, judgment under §§ 8.01-516.1 and 8.01-519 may be for such costs, and against such party, as the court may deem just.
Code 1950, § 8-449; 1977, c. 617.

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