Civil Litigation Brief
Menu
  • Home
  • About
  • Membership Plans
  • Login
Updates and Commentary on Civil Procedure, by Gordon Exall, Barrister, Kings Chambers
Browse: Home » 2016 » May

WITNESS EVIDENCE, RELIABILITY AND CREDIBILITY: WHY EVERYONE SHOULD READ GESTMIN (OR FAILING THAT, MY SUMMARY)

May 31, 2016 · by gexall · in Applications, Avoiding negligence claims, Civil evidence, Members Content, Uncategorized, Useful links, Witness statements

I spent the afternoon lecturing to a group of enthusiastic lawyers about the importance of witness statements (and where things can, and do go wrong). I was worried that the enthusiasm  could be waning waning when I took them, in…

PROVING THINGS 20: ALLEGATIONS OF IMPROPER CONDUCT HAVE TO BE PROVEN: INDEMNITY COSTS ORDERED

May 30, 2016 · by gexall · in Assessment of Costs, Civil evidence, Conduct, Members Content, Uncategorized

In Collins -v- Thanet District Council Collins anor v Thanet DC anor (19 4 16)(Jud) 2 [2016] EWHC 1008 (QB) His Honour Judge Yelton (sitting as a Judge of the High Court) considered the evidence available to support allegations of misfeasance…

IT'S NOT JUST WINNING BUT HOW YOU PLAY THE GAME: COSTS ORDERS WHEN BOTH PARTIES ASSERT THAT THEY HAVE "WON"

May 29, 2016 · by gexall · in Assessment of Costs, Costs, Costs budgeting, Members Content, Uncategorized

In Milanese -v- Leyton Orient Football Club Limited [2016] EWHC 1263 (QB) Mrs Justice Whipple considered issues relating to costs after a case in which each party claimed to have won. “I remind myself that this is an area where…

ELEMENTARY EVIDENCE: THE COURTS DO NOT FOLLOW THE APPROACH OF SHERLOCK HOLMES

May 27, 2016 · by gexall · in Civil evidence, Members Content, Uncategorized, Witness statements

The judgment of Mrs Justice Carr DBE in Cooper -v-Thameside Company Ltd [2016] EWHC 1248 (TCC) contains an interesting, and ultimately important, consideration of the judicial approach to fact finding.  It is interesting that this £6.5 million depended, primarily, on…

EXPERT SHOPPING: CHANGING EXPERTS AND DISCLOSURE OF REPORTS

May 27, 2016 · by gexall · in Applications, Civil evidence, Members Content, Uncategorized, Witness statements

Suspicions are often aroused when an party wants to change expert mid-way through a case.  There is, usually, a requirement that before a court grants permission to instruct a new expert the previous report has to be disclosed. The case…

QOCS CONTINUE TO APPLY ON APPEAL: HIGH COURT DECISION

May 26, 2016 · by gexall · in Appeals, Costs, Members Content, QOCS, Uncategorized

In Parker -v- Butler [2016] EWHC 1251 (QB) Mr Justice Edis decided that QOCS protection continued to apply when a claimant appealed. “To construe the word “proceedings” as excluding an appeal which was necessary if he were to succeed in…

SOCIAL MEDIA AND CIVIL EVIDENCE: WHAT DID YOU SAY ON LINKEDIN?

May 26, 2016 · by gexall · in Civil evidence, Civil Procedure, Members Content

Social media played a part in the decision of Registrar Derrett in Green -v- Marston [2016] EWHC B11 (Ch). It illustrates the importance of social media across many fields of litigation. THE CASE The claimant was the liquidator of a…

STATEMENTS OF CASE & THE STATEMENT OF TRUTH: CAN A PARTY ARGUE TWO DIFFERENT THINGS?

May 25, 2016 · by gexall · in Applications, Members Content, Statements of Case, Statements of Truth, Uncategorized

There are some interesting observations by Mr Justice Leggatt in ED&F Sugar ltd -v- T&L Sugar Ltd [2016] EWHC 272 (Comm). KEY POINTS A statement of truth which supported particulars of claim was a statement of fact. An assertion in…

I WROTE LOTS OF UNEDIFYING, AGGRESSIVE AND UNCOOPERATIVE LETTERS: LOOK WHERE IT GOT ME

May 25, 2016 · by gexall · in Appeals, Case Management, Civil evidence, Conduct, Members Content, Proportionality, Uncategorized

One of aspects of the judgment in  McTear -v- Englehard [2016] EWCA Civ 487 that could easily be overlooked is the observations of Lord Justice Vos in relation to the nature of the  correspondence between the parties. “It would seem…

COURT OF APPEAL OVERTURN REFUSAL TO GRANT RELIEF FROM SANCTIONS: RE-TRIAL NECESSARY

May 24, 2016 · by gexall · in Appeals, Civil evidence, Civil Procedure, Disclosure, Members Content, Relief from sanctions, Uncategorized, Witness statements

In McTear -v- Engelhard [2016] EWCA Civ 487 today the Court of Appeal overturned a refusal to grant relief from sanctions.  Consequently there will have to be a re-trial. (The judgment at first instance in this Case was considered in…

FAILING TO PLEAD CASE FULLY CAN LEAD TO YOUR ACTION GOING DOWN THE DRAIN

May 23, 2016 · by gexall · in Amendment, Appeals, Costs, Members Content, Statements of Case, Uncategorized

The Court of Appeal decision today in the case  of Court -v- Van Dijk [2016] EWCA Civ 438  is the third case within a month where the courts have considered the adequacy of statements of case.  It is also has…

WITNESS STATEMENTS CANNOT REPLACE PLEADINGS &"CUT AND PASTE" WITNESS STATEMENTS ARE UNLIKELY TO IMPRESS

May 22, 2016 · by gexall · in Amendment, Applications, Costs, Members Content, Statements of Case, Uncategorized, Witness statements

In Chong -v- Alexander [2015] EWHC 735 (CH) Richard Spearman Q.C. (sitting as a Deputy Judge) had to consider several issues relating to statements of case and witness evidence. “…the typographical error (“At” instead of “As”), is replicated in a…

PROVING THINGS 19: PROVE SERVICE OR YOU COULD BE CAUGHT OUT

May 20, 2016 · by gexall · in Applications, Civil evidence, Members Content, Serving documents, Uncategorized, Witness statements

A regular theme of this series has been to examine how cases fail, in full or partially, because of the absence of evidence. This can be seen in a decision of the First-Tier Tribunal Tax Chamber in England and Wales…

EXPERTS:YOU'RE NOT RIGHT JUST BECAUSE YOU'RE FAMOUS: A DECISION NOT WRITTEN ON THE BACK OF A FAG PACKET

May 19, 2016 · by gexall · in Civil evidence, Expert evidence, Experts, Members Content, Uncategorized

The judgment of Mr Justice Green  in British American Tobacco (UK) Limited -v- Secretary of State for Health [2016] EWHC 1169 is 1,000 paragraphs long. It covers many aspects of law and procedure. I want to concentrate upon one issue….

PROVING THINGS 18: DAMAGES; CAR HIRE; PROOF AND SUMMARY JUDGMENT

May 19, 2016 · by gexall · in Civil evidence, Damages, Members Content, Statements of Case, Summary judgment, Uncategorized

The burden is (usually) on a claimant to prove a loss.  There is an interesting discussion on the need to prove “need” in the decision of District Judge Read in Frankland -v- U.K. Insurance Ltd (10th August 2015) which was…

SUCCESS FEES:DEDUCTIONS FROM DAMAGES WHERE CLAIMANT IS UNDER A DISABILITY

May 19, 2016 · by gexall · in Applications, Assessment of Costs, Conditional Fee Agreements, Members Content, Success Fees, Uncategorized

The issue of deductions of success fees in cases when the claimant is under a disability remains a difficult one. I am grateful to Jane McBennett of Morrish Solicitors in Bradford for the attached note in relation to a court…

FAILURE TO PAY THE CORRECT COURT FEE DOES NOT LEAD TO STRIKING OUT OF AN ACTION

May 17, 2016 · by gexall · in Amendment, Applications, Civil Procedure, Limitation, Members Content, Striking out, Uncategorized

The decision in  Lewis -v- Ward Hadaway [2015] EWHC 3503 (Ch)  has led to considerable interest (and it has to be said) some hyperbole and opportunistic applications. The case is often misunderstood. In Bhatti -v- Ashghar [2016] EWHC 1049 (QB)…

THE THIRD PARTIES (RIGHTS AGAINST INSURERS) ACT 2010 1: 5 INITIAL POINTS

May 17, 2016 · by gexall · in Applications, Insolvency, Members Content, Uncategorized, Useful links

The Third Party (Rights Against Insurers) Act 2010 is shortly to come into force. Here are 5 key points. Here we look at the implementation date, legislative history and basic definitions of the Act. A BRIEF OVERVIEW The Act allows…

PEREMPTORY ORDERS, EXTENSIONS OF TIME AND WITNESS CREDIBILITY

May 16, 2016 · by gexall · in Applications, Extensions of time, Members Content, Peremptory orders, Relief from sanctions, Uncategorized

In Suez Fortune Investments Ltd -v- Talbot Underwriting Ltd [2016]  EWHC 1085 (Comm) Mr Justice Flaux considered an application to extend time or vary a peremptory order. “I consider that a claimant in contumelious breach of Court Orders whose claim…

CIVIL EVIDENCE: IS EVIDENCE OBTAINED BY TORTURE ADMISSIBLE?

May 16, 2016 · by gexall · in Civil evidence, Members Content, Uncategorized, Witness statements

The question of whether evidence obtained by torture in civil proceedings is one I never envisaged having address. However it was an issue considered in the judgment of Mr Justice Knowles MBE In Shangang Shipping Company Ltd -v- HNA Group…

WITNESS STATEMENTS: ALTERATIONS AND THE FALLIBLE MEMORY: A SCIENTIFIC STUDY

May 16, 2016 · by gexall · in Civil evidence, Members Content, Uncategorized, Witness statements

It is worthwhile anyone involved in assessment of witness evidence reading the post by Julia Shaw in Scientific America today: Do you suffer from memory blindness. The post refers back to the altered witness statements in the Hillsborough enquiries in the…

LEARNING HOW TO PROVE THINGS: A BASIC SKILL THAT NEEDS HONING

May 15, 2016 · by gexall · in Applications, Civil evidence, Expert evidence, Members Content, Uncategorized, Witness statements

As part of the occasional series which jogs peoples memories about New Year’s resolutions for 2016 I am revisiting resolution number 6: “learn how to prove things”. A very basic skill in the litigator’s armoury, but one which is barely…

THE SUPREME COURT CONSIDERS THE QUESTION OF EXPENSIVE BUNDLES: COULD IT BE CHEAPER ELECTRONICALLY?

May 15, 2016 · by gexall · in Bundles, Case Management, Civil evidence, Costs, Members Content, Uncategorized

Since Supreme Court decisions on trial bundles are few and far between I am  compelled to write about the judgment in Eclipse Film Partners -v- Commissioners for Her Majesty’s Revenue & Customs [2016] UKSC 24.  Here the Court considered bundles…

CIVIL EVIDENCE: ABSENT DOCTOR DOES NOT LEAD TO AN ADVERSE INFERENCE

May 13, 2016 · by gexall · in Civil evidence, Members Content, Uncategorized, Witness statements

CIVIL In Manzi -v- King’s College Hospital NHS Foundation Trust [2016] EWHC 1101 (QB) Mr Justice Nicol considered the question of whether it was appropriate for a court to draw adverse inferences when a witness is not called. “… in…

EXTENDING TIME FOR SERVICE OF A CLAIM FORM: PROSECCO MAY HELP

May 12, 2016 · by gexall · in Appeals, Extensions of time, Insolvency, Members Content, Service of the claim form, Uncategorized

There have been numerous cases relating to extension of the claim form on this blog. I can’t remember one which ended well for the claimant.  However the claimant was successful in the Instone -v- Prosecco (Leeds) LImited [2016] EW Misc…

ASSIGNMENT OF CFAS: ROUND 2: ASSIGNMENT CAN TAKE PLACE

May 11, 2016 · by gexall · in Appeals, Assessment of Costs, Costs, Members Content, Success Fees, Uncategorized

In the judgment today in Jones -v- Spire Healthcare Ltd His Honour Graham Wood QC had to determine the issue of whether a CFA can be assigned. The full judgment is an attachment to this post and is available here…

PROVING THINGS 17: HEADS OF DAMAGE THAT WERE "ENTIRELY BOGUS"

May 11, 2016 · by gexall · in Civil evidence, Damages, Members Content, Uncategorized, Witness statements

The case of Perma-Soil UK Limited -v- Williams & Flintshire County Council [2016] EWHC 1087 (QB) was an unusual one. The claimant (unsuccessfully) brought a claim for damages for misfeasance in public office. However I want to look at the…

WITNESS STATEMENTS & HILLSBOROUGH 3: CONFIRMATION BIAS AT ITS WORST

May 10, 2016 · by gexall · in Civil evidence, Members Content, Uncategorized, Witness statements

Much has been written and broadcast about Hillsborough. I am here concentrating on one small part of the process: the initial gathering of evidence.  It was the flawed nature of this process that led to problems for the next two…

APPLICATION TO WITHDRAW ADMISSION REFUSED: SUMMARY JUDGMENT GRANTED

May 10, 2016 · by gexall · in Admissions, Applications, Conduct, Members Content, Uncategorized

NB – THE JUDGE’S DECISION NOT TO ALLOW THE FIRST DEFENDANT TO WITHDRAW FROM THE ADMISSION WAS SUBSEQUENTLY OVERTURNED ON APPEAL. See the post here. The judgment yesterday in Wood -v- Days Health UK Ltd & Others [2016] WHC 1079…

FUNDAMENTAL DISHONESTY: THE PAST 12 MONTHS: A ROUND UP

May 9, 2016 · by gexall · in Applications, Case Management, Civil evidence, Civil Procedure, Members Content, QOCS, Uncategorized, Useful links

On May 10th last year I did a round up of cases and commentary on the issue of fundamental dishonesty.  Here we look at cases and commentary in the past 12 months. CASES Most of the cases are inevitably first…

HILLSBOROUGH AND WITNESS STATEMENTS 2: THE EARLY MIXING OF FACT AND OPINION

May 9, 2016 · by gexall · in Civil evidence, Members Content, Uncategorized, Witness statements

The previous post in this series looked at the issues that arose when the solicitors for the police force sent out a missive asking the police officers on the ground for their “comment and impression”.  There was an immediate mixing…

EXTENSION OF TIME FOR SERVICE OF THE CLAIM FORM SET ASIDE: A CASE ALL CLAIMANTS SHOULD KNOW

May 6, 2016 · by gexall · in Appeals, Members Content, Service of the claim form, Serving documents, Uncategorized

A really easy way for a claimant lawyer to get sued is to hold onto the claim form. Cases relating to late or mis-service of the claim form are a regular feature of this blog.  It is equally dangerous for…

THE INTERCHANGE BETWEEN LAWYERS & EXPERTS: A DIFFICULT ISSUE

May 5, 2016 · by gexall · in Conduct, Expert evidence, Experts, Members Content, Uncategorized

In a week where there is a report of an application being made for a doctor to be committed for contempt* it is prudent to consider that difficult issue of the relationship between the lawyers in a case and the…

THE MEDICAL EVIDENCE IN SUPPORT OF AN APPLICATION TO ADJOURN CANNOT BE IGNORED

May 5, 2016 · by gexall · in Adjournments, Appeals, Civil Procedure, Expert evidence, Members Content, Uncategorized

A post last week noted the decision of the Court of Appeal in TBO Investments Ltd -v- Mohun Smith EWCA Civ 403 where the court stated that an application under CPR 39.3 should have been allowed when a defendant failed…

LATE SERVICE OF NOTICE OF APPEAL: COUNSEL'S ERROR DOES NOT AMOUNT TO A GOOD REASON

May 5, 2016 · by gexall · in Appeals, Applications, Extensions of time, Members Content, Relief from sanctions, Uncategorized

In the judgment today in Turner -v- South Cambridgeshire District Council [2016] EWHC 1017(Admin)Mr Justice Warby considered the Denton guidance in relation to an application to appeal out of time. Among other factors he rejected the idea that an error…

RULES EXIST TO ASSIST RESOLUTION OF ISSUES AND NOT TO THROW UP TECHNICAL OBSTACLES

May 4, 2016 · by gexall · in Amendment, Appeals, Applications, Members Content, Uncategorized

In Williams -v- Devon County Council [2016] EWCA Civ 419 the Court of Appeal upheld a decision by a judge to allow substitution of a named individual in place of a group. “These rules exist to enable the court to…

STATEMENT THAT THE APPELLANTS WERE CROOKS DID NOT GIVE RISE TO GROUNDS FOR RE-OPENING AN APPEAL

May 4, 2016 · by gexall · in Appeals, Applications, Members Content, Uncategorized

In the judgment given today in Goldtrail Travel Limited -v- Aydin [2016] EWCA Civ 439 the Court of Appeal rejected an application under CPR 52.17 to re-open an appeal on the grounds of bias. THE CASE The Court of Appeal…

WHEN A PARTY FAILS TO PAY INTERLOCUTORY COSTS: MAKE A PEREMPTORY ORDER

May 3, 2016 · by gexall · in Applications, Assessment of Costs, Costs, Members Content, Peremptory orders, Uncategorized

In Peak Hotels -v- Tarek Investments Ltd [2016] EWHC 690 (Ch) Mrs Justice Asplin considered the appropriate approach when a party  has failed to pay an interlocutory costs order.  There is a succinct summary of the relevant case law. “If…

RTA TRIAL FEE RECOVERABLE IF CASE SETTLES AT TRIAL

May 3, 2016 · by gexall · in Appeals, Assessment of Costs, Costs, Members Content, RTA Protocol, Uncategorized

In Mendes -v- Hocthtief (UK) Construction Ltd [2016] EWHC 976 (QB) Mr Justice Coulson decided a point of some importance: is the RTA Protocol brief fee recoverable if a matter settles at trial. “… there are sound policy reasons for…

Subscribe to Blog via Email

Enter your email address to subscribe to this blog and receive notifications of new posts by email. Subscription notifies you of a new post, it does not give you access to members' content.

Join 16.8K other subscribers

Recent Posts

  • PART 36 IN THE COURT OF APPEAL TODAY: DIGGING DEEPER 3: SO WHY DID THE CLAIMANT LOSE? PLUS – THE STING IN THE TAIL FOR DEFENDANTS…
  • PART 36 IN THE COURT OF APPEAL TODAY: DIGGING DEEPER 2: WAS AN OFFER ON LIABILITY EFFECTIVE IN THIS CONTEXT?
  • PART 36 IN THE COURT OF APPEAL TODAY: DIGGING DEEPER (1): WHAT IS THE DIFFERENCE BETWEEN A “JUDGMENT” AND AN “ORDER” ?
  • COURT OF APPEAL DECISION ON PART 36 THIS MORNING: AN OFFER OF 90% ON LIABILITY COULD POTENTIALLY HAVE PART 36 CONSEQUENCES WHEN A CLAIM IS APPROVED ON DAMAGES (BUT DID NOT IN THIS CASE).
  • THROWBACK FRIDAY: EXTENDING TIME FOR SERVICE OF THE CLAIM FORM ALWAYS WAS (AND REMAINS) A RISKY BUSINESS

Top Posts

  • PART 36 IN THE COURT OF APPEAL TODAY: DIGGING DEEPER 2: WAS AN OFFER ON LIABILITY EFFECTIVE IN THIS CONTEXT?
  • PART 36 IN THE COURT OF APPEAL TODAY: DIGGING DEEPER 3: SO WHY DID THE CLAIMANT LOSE? PLUS - THE STING IN THE TAIL FOR DEFENDANTS...
  • COURT OF APPEAL DECISION ON PART 36 THIS MORNING: AN OFFER OF 90% ON LIABILITY COULD POTENTIALLY HAVE PART 36 CONSEQUENCES WHEN A CLAIM IS APPROVED ON DAMAGES (BUT DID NOT IN THIS CASE).
  • PART 36 IN THE COURT OF APPEAL TODAY: DIGGING DEEPER (1): WHAT IS THE DIFFERENCE BETWEEN A "JUDGMENT" AND AN "ORDER" ?
  • AN APPLICATION FOR PRE-ACTION DISCLOSURE: THIS IS NOT A "FISHING EXPEDITION" AND IT IS AN APPROPRIATE CASE TO MAKE AN ORDER

Archives

Blogroll

  • Fatal Accident Law
  • Legal Futures
  • Personal injury: Liability and Damages

Books

  • Munkman & Exall on Damages for Personal Injuries and Death 15th ed
  • The APIL Guide to Fatal Accidents 4th edition

Useful Links

  • Buntools (for preparing PDF Bundles)
  • Kings Chambers
  • Kings Chambers Costs & Litigation Funding
  • Kings Chambers Serious Injury
  • The Civil Procedure Rules
  • The Law Society Gazette
  • The National Archives Recently Published Judgments
  • The Senior Court Costs Office Guide 2025
  • www.Bailii.org

Copyright

© Gordon Exall, Exall Legal Training, Civil Litigation Brief, 2013-2025. Unauthorised use and or duplication of the material contained on this blog without permission is strictly prohibited.
Privacy & Cookies: This site uses cookies. By continuing to use this website, you agree to their use.

To find out more, including how to control cookies, see here: Cookie Policy
  • Membership Terms and Conditions
  • Privacy Policy
  • Advertising Policy
  • Copyright
  • Legal Disclaimer

Copyright © 2026 Civil Litigation Brief

Powered by Big Yellow Workshop