Civil Litigation Brief
Menu
  • Home
  • About
  • Membership Plans
  • Login
Updates and Commentary on Civil Procedure, by Gordon Exall, Barrister, Kings Chambers, Leeds, Manchester & Birmingham. 4-5 Gray's Inn Square, London.
Browse: Home » 2019 » Page 13
APPEALS FROM DISTRICT JUDGES WHEN CASES HAVE BEEN RELEASED TO THEM:  A POINT TO WATCH

APPEALS FROM DISTRICT JUDGES WHEN CASES HAVE BEEN RELEASED TO THEM: A POINT TO WATCH

January 15, 2019 · by gexall · in Appeals, Members Content

The judgment of Mr Justice Morgan in Hilton v Cosnier [2018] EWHC 3728 (Ch) highlights a practical issue that is easy to overlook.  Cases, that are normally tried by a Circuit Judge, can be released to a District Judge. Appeals from…

LEGAL FUTURES CIVIL LITIGATION CONFERENCE 19th MARCH 2019 (IF CARLSBERG DID CONFERENCES ABOUT LITIGATION...)

LEGAL FUTURES CIVIL LITIGATION CONFERENCE 19th MARCH 2019 (IF CARLSBERG DID CONFERENCES ABOUT LITIGATION…)

January 15, 2019 · by gexall · in Civil Procedure, Courses, Members Content

The Legal Futures Civil Litigation Conference is on the 19th March this year at the Grand Connaught Rooms in London.  Details of the day and how to book can be found here.   This should be a highly informative day. “This conference…

"A MISUSE OF JUDICIAL POWER":  A WITNESS SPEAKING TO LAWYER IN THE COURSE OF GIVING EVIDENCE  DOES NOT JUSTIFY COMMITTAL OR STRIKING OUT A CASE

“A MISUSE OF JUDICIAL POWER”: A WITNESS SPEAKING TO LAWYER IN THE COURSE OF GIVING EVIDENCE DOES NOT JUSTIFY COMMITTAL OR STRIKING OUT A CASE

January 15, 2019 · by gexall · in Abuse of Process, Civil Procedure, Committal proceedings, Members Content, Striking out

In the judgment today in Hughes Jarvis Ltd v Searle & Anor [2019] EWCA Civ the Court of Appeal robustly overturned a decision committing a witness to prison and striking out a case.  It was found that the trial judge had,…

THE DEFENDANT'S "WRONG" APPLICATION TO DISPUTE JURISDICTION WAS STILL VALID: DEFENDANT ALLOWED EXTENSION OF TIME AND TO CORRECT APPLICATION

THE DEFENDANT’S “WRONG” APPLICATION TO DISPUTE JURISDICTION WAS STILL VALID: DEFENDANT ALLOWED EXTENSION OF TIME AND TO CORRECT APPLICATION

January 15, 2019 · by gexall · in Appeals, Applications, Civil Procedure, Extensions of time, Members Content, Service of the claim form, Serving documents

Twelve years ago, in  Hoddinott and others v Persimmon Homes (Wessex) Limited [2007] EWCA Civ 1203; [2008] 1 WLR 806, the Court of Appeal held that the correct way for a defendant to challenge the validity of a claim form was to issue…

CLAIM FORM CASE IN THE COURT OF APPEAL: SERVICE OF CLAIM FORM BY UNAUTHORISED BODY DOES NOT RENDER SERVICE VOID (ALTHOUGH IT IS STILL NAUGHTY)

CLAIM FORM CASE IN THE COURT OF APPEAL: SERVICE OF CLAIM FORM BY UNAUTHORISED BODY DOES NOT RENDER SERVICE VOID (ALTHOUGH IT IS STILL NAUGHTY)

January 15, 2019 · by gexall · in Appeals, Avoiding negligence claims, Members Content, Service of the claim form, Serving documents

We have managed to get to the 15th day of the year without a service of the claim form case, to compensate for this there are two today.   In Ndole Assets Ltd v Designer M&E Services UK Ltd [2018] EWCA Civ…

CIVIL PROCEDURE BACK TO BASICS 23: YOU CAN'T SUE THE DEAD: BUT YOU CAN SUE THEIR ESTATE:  WHAT TO DO IF THERE IS NO ESTATE

CIVIL PROCEDURE BACK TO BASICS 23: YOU CAN’T SUE THE DEAD: BUT YOU CAN SUE THEIR ESTATE: WHAT TO DO IF THERE IS NO ESTATE

January 14, 2019 · by gexall · in Applications, Civil Procedure, Fatal Accidents, Members Content

This post is due to a search term that arrived on this blog today “how to join a deceased person to litigation”.   The simple answer is that you can’t. An action has to be against the deceased’s estate. Attempting to…

BREXIT AND CIVIL PROCEDURE:  EXPERTS ARE NOT BE CROSS EXAMINED ON FORESEEABILITY OF UK LEAVING THE EU

BREXIT AND CIVIL PROCEDURE: EXPERTS ARE NOT BE CROSS EXAMINED ON FORESEEABILITY OF UK LEAVING THE EU

January 14, 2019 · by gexall · in Brexit, Civil evidence, Expert evidence, Experts, Members Content

This is a far less exciting case than the headline suggests, however it is the first  case I have seen about the impact of Brexit on civil procedure (albeit indirectly). In Canary Wharf (Bp4) T1 Ltd & Ors v European Medicines…

ADVOCACY THE JUDGE'S VIEW SERIES 3: PART 10: THE LAST POST: A CHANCE TO LOOK BACK ON THE THREE SERIES (SO FAR)

ADVOCACY THE JUDGE’S VIEW SERIES 3: PART 10: THE LAST POST: A CHANCE TO LOOK BACK ON THE THREE SERIES (SO FAR)

January 13, 2019 · by gexall · in Advocacy, Members Content, Useful links

We have looked at guidance from judges from many parts of the world.  Looking at what judges say about the way that cases are brought before them is a good way for advocates (and litigation lawyers in general) to know…

ADVOCACY: THE JUDGE'S VIEW: SERIES 3: PART 9: "DON'T BITCHSLAP YOUR OPPONENT": GUIDANCE FROM A CRANKY JUDGE

ADVOCACY: THE JUDGE’S VIEW: SERIES 3: PART 9: “DON’T BITCHSLAP YOUR OPPONENT”: GUIDANCE FROM A CRANKY JUDGE

January 13, 2019 · by gexall · in Members Content, Written advocacy

Here we are going to the USA and looking at guidance given by Federal Judge Richard G Kopf in his blog Hercules and the Umpire.  As every the aim here is to get you to read the original (follow the…

YOUR CHANCE TO WIN A SIGNED SECRET BARRISTER T-SHIRT: ONLINE AUCTION STARTS TODAY

YOUR CHANCE TO WIN A SIGNED SECRET BARRISTER T-SHIRT: ONLINE AUCTION STARTS TODAY

January 11, 2019 · by gexall · in Charity, Contest, Charity,, Members Content

With the help of the Secret Barrister we are once again raising money for the Billable Hour Charity, giving you a chance to win a signed Secret Barrister T-shirt.   THE SHIRT This is one of the T-shirts designed for…

DEFENDANT'S APPLICATION FOR PRE-ACTION DISCLOSURE REFUSED: AN ORDER WOULD NOT SAVE COSTS OR ASSIST THE DISPUTE TO BE RESOLVED WITHOUT PROCEEDINGS

DEFENDANT’S APPLICATION FOR PRE-ACTION DISCLOSURE REFUSED: AN ORDER WOULD NOT SAVE COSTS OR ASSIST THE DISPUTE TO BE RESOLVED WITHOUT PROCEEDINGS

January 10, 2019 · by gexall · in Appeals, Applications, Damages, Disclosure, Members Content

In Lacey v Leonard [2018] EWHC 3528 (QB) Mrs Justice Slade DBE upheld a decision refusing the defendant’s application for pre-action disclosure.  The primary ground for refusal was that disclosure of medical records, and various documents relating to employment, would not…

LITIGANTS IN PERSON AND THE USE OF COURT TIME: AN EXAMPLE OF THINGS TO COME?

LITIGANTS IN PERSON AND THE USE OF COURT TIME: AN EXAMPLE OF THINGS TO COME?

January 10, 2019 · by gexall · in Access to justice, Appeals, Applications, Litigants in person, Members Content

The case of  Zaman v Portsmouth City Council [2018] EWHC 3592 (QB) makes interesting reading for anyone concerned about the effect that the increasing number of litigants in person could have on the court system. THE CASE The claimant sought payment…

FIXED COSTS DO NOT APPLY WHEN THEY ARE INCONSISTENT WITH THE TERMS OF CONSENT ORDER: JUDGMENT ON APPEAL IN THE COUNTY COURT

FIXED COSTS DO NOT APPLY WHEN THEY ARE INCONSISTENT WITH THE TERMS OF CONSENT ORDER: JUDGMENT ON APPEAL IN THE COUNTY COURT

January 9, 2019 · by gexall · in Appeals, Case Management, Costs, Fixed Costs, Members Content, Uncategorized

NB THIS DECISION WAS OVERTURNED BY THE COURT OF APPEAL IN Ho v Adelekun [2019] EWCA Civ 1988, see the discussion here.  I am grateful to Sam Hayman and Tom Jenkinson  from Bolt Burdon Kemp  for sending me a copy…

WITNESS STATEMENTS AND TRANSLATION: WHY YOU CAN'T RELY ON PD 22 IN RELATION TO WITNESS STATEMENTS

WITNESS STATEMENTS AND TRANSLATION: WHY YOU CAN’T RELY ON PD 22 IN RELATION TO WITNESS STATEMENTS

January 8, 2019 · by gexall · in Civil evidence, Civil Procedure, Members Content, Witness statements

This is the third post on this subject in one day.  Someone responded to the first post on the need to for witness statements to be in the language of the witness by asserting that Practice Direction 22 could be…

THE STATEMENT OF TRUTH AND WITNESSES WITH POOR ENGLISH: PRACTICE DIRECTION 22

THE STATEMENT OF TRUTH AND WITNESSES WITH POOR ENGLISH: PRACTICE DIRECTION 22

January 8, 2019 · by gexall · in Civil evidence, Civil Procedure, Members Content, Statements of Case, Statements of Truth

The post earlier today about witness statements in a foreign language led (almost immediately) to a telephone enquiry as to what happens when a party cannot read or understand the statement of truth in a statement of case.  The answer…

WHEN A WITNESS CANNOT SPEAK ENGLISH:  INTERPRETING THE RULES: GUIDANCE FROM THE CASES

WHEN A WITNESS CANNOT SPEAK ENGLISH: INTERPRETING THE RULES: GUIDANCE FROM THE CASES

January 8, 2019 · by gexall · in Civil evidence, Civil Procedure, Members Content, Witness statements

If a witness cannot speak English and a witness statement is required what needs to be done? There are several cases where the issue of translation has caused a problem at trial.  The best guidance comes from the Family Division….

DEFENDANT ORDERED TO PAY COSTS AFTER REFUSING TO PAY PRE-ACTION COSTS: COURT OF APPEAL REFUSES TO GIVE PERMISSION TO APPEAL

DEFENDANT ORDERED TO PAY COSTS AFTER REFUSING TO PAY PRE-ACTION COSTS: COURT OF APPEAL REFUSES TO GIVE PERMISSION TO APPEAL

January 7, 2019 · by gexall · in Appeals, Applications, Costs, Members Content, Part 36

In November last year I wrote about the case of Ayton -v- RSM Bentley Bennison & Ors [2018] EWHC 2851 (QB).  This was a case in which the defendant refused to pay cost incurred prior to issue. Proceedings were issued and…

ARROGANT, RUDE, SEXIST (AND AT TIMES BARELY LITERATE): THE MINISTRY OF JUSTICE: WE ALL DESERVE BETTER MUCH, MUCH BETTER

January 6, 2019 · by gexall · in Abuse of Process, Access to justice, Members Content

My “litigator’s New Year’s resolution” for 2019 was to recommend that everyone read more of Emily Dugan’s work on exposing the impact of the cuts at the Ministry of Justice. When I wrote the “resolution” I could not have conceived…

CIVIL PROCEDURE BACK TO BASICS 22: WHEN THE CLAIMANT ADOPTS ALLEGATIONS OF CONTRIBUTORY NEGLIGENCE: HOIST ON YOUR OWN PETARD

CIVIL PROCEDURE BACK TO BASICS 22: WHEN THE CLAIMANT ADOPTS ALLEGATIONS OF CONTRIBUTORY NEGLIGENCE: HOIST ON YOUR OWN PETARD

January 6, 2019 · by gexall · in Applications, Members Content, Statements of Case

This post follows on from the previous post in relation to pleading the Defendant’s case in the alternative.  Here we are looking at cases where a defendant pleads allegations of negligence and the claimant uses  those allegations as allegations against the…

SKELETON ARGUMENTS: BE SUCCINCT AND TO THE POINT: "THE ISSUE WAS ALL BUT LOST IN THE PLETHORA OF PAPER": COURT OF APPEAL FIRES WARNING SHOT

SKELETON ARGUMENTS: BE SUCCINCT AND TO THE POINT: “THE ISSUE WAS ALL BUT LOST IN THE PLETHORA OF PAPER”: COURT OF APPEAL FIRES WARNING SHOT

January 4, 2019 · by gexall · in Appeals, Applications, Civil Procedure, Members Content, Written advocacy

 Now that Lord Justice Jackson has retired someone needs to take his place to provide the (more or less quarterly) reminder to practitioners to keep skeleton arguments short and to the point.   Step in Lord Justice Hickinbottom in Harverye v The…

EXPERT WITNESS INDEPENDENCE AND IMPARTIALITY: HOW DO YOU DEAL WITH THE "BOMBASTIC BULLSHITTER"? A CHECKLIST TO ENSURE EXPERT IMPARTIALITY

EXPERT WITNESS INDEPENDENCE AND IMPARTIALITY: HOW DO YOU DEAL WITH THE “BOMBASTIC BULLSHITTER”? A CHECKLIST TO ENSURE EXPERT IMPARTIALITY

January 4, 2019 · by gexall · in Expert evidence, Experts, Members Content

I am grateful to Professor Penny Cooper for sending me a copy of the report she authored with Dr Michelle Mattison for the Expert Witness Institute – “Towards Expert Witness Independence and Impartiality”.  This post is just a snapshot, to…

CIVIL PROCEDURE: BACK TO BASICS 21: PLEADING IN THE ALTERNATIVE:  BINKS -v- SECURICOR

CIVIL PROCEDURE: BACK TO BASICS 21: PLEADING IN THE ALTERNATIVE: BINKS -v- SECURICOR

January 3, 2019 · by gexall · in Appeals, Case Management, Members Content, Statements of Truth

Can a claimant plead two alternative cases?  This is an issue that often arises in personal injury litigation, where the basic facts are disputed.  A claimant may wish to argue that the defendant remains liable – even on the defendant’s…

BEING A LITIGATOR: “WHAT I’D TELL A YOUNGER ME" 2: BRIE STEVENS-HOARE QC

BEING A LITIGATOR: “WHAT I’D TELL A YOUNGER ME” 2: BRIE STEVENS-HOARE QC

January 2, 2019 · by gexall · in Applications, Avoiding negligence claims, Civil Procedure, Members Content

In the second in this series I popped into chambers at Hardwicke and  spoke to  property and probate  law litigator Brie Stevens-Hoare QC.  A QC since 2013  Brie is also  Deputy Adjudicator to HM Land Registry and sits as a fee-paid…

ADVERSE INFERENCES DRAWN WHEN SOLICITOR DID NOT GIVE EVIDENCE: IF YOU'VE HAD £22 MILLION YOU NEED TO EXPLAIN IT

ADVERSE INFERENCES DRAWN WHEN SOLICITOR DID NOT GIVE EVIDENCE: IF YOU’VE HAD £22 MILLION YOU NEED TO EXPLAIN IT

January 2, 2019 · by gexall · in Civil evidence, Civil Procedure, Members Content, Witness statements

In The Lord Chancellor v Blavo & Co Solictors Ltd & Anor [2018] EWHC 3556 (QB) Mr Justice Pepperall found it was appropriate to draw adverse inferences when key  participants did not give evidence.  It is another example of the principles…

A NEW YEAR’S RESOLUTION FOR LITIGATORS: READ BUZZFEED MORE OFTEN: FIND OUT WHAT JUDGES REALLY THINK AND THE MOJ’S HIGHLY “SELECTIVE” USE OF STATISTICS

January 1, 2019 · by gexall · in Access to justice, Members Content

I have written before about the impressive work done by the journalist Emily Duggan on Buzzfeed News. Emily is one of the people who keeps a close, and sceptical, eye on what we are being told about reforms to the …

← Previous 1 … 12 13

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

  • COST BITES 310: COSTS, CONDUCT AND ADR: THE DEFENDANTS HAD NOT BEEN UNREASONABLE IN THEIR APPROACH TO MEDIATION: IT WOULD HAVE BEEN WHOLLY REASONABLE FOR THEM TO REFUSE TO MEDIATE IN ANY EVENT
  • WITNESS EVIDENCE WEDNESDAY: WHAT SHOULD A JUDGE DO WHEN THE FACTS ARE DISPUTED BUT WITNESSES ARE NOT CALLED TO GIVE EVIDENCE?
  • FUNDAMENTAL DISHONESTY AND CONTEMPT OF COURT: CLAIMANT BROUGHT A FRAUDULENT £3 MILLION CLAIM: SENTENCE OF IMPRISONMENT IMPOSED
  • CONTRIBUTORY NEGLIGENCE IN ROAD TRAFFIC CASES: DO ALL ROADS LEAD TO FROOM? WEBINAR 19th NOVEMBER 2025
  • MAZUR MATTERS 39: CILEX APPLIES TO APPEAL MAZUR DECISION

Top Posts

  • MAZUR MATTERS 39: CILEX APPLIES TO APPEAL MAZUR DECISION
  • THE CURRENT IMPORTANCE OF PLEADINGS 37: PARTICULARS OF CLAIM STRUCK OUT: THEY "FAIL TO FULFIL ANY OF THE REQUIREMENTS IMPOSED FOR, AND PURPOSES TO BE SERVED BY, PARTICULARS OF CLAIM"
  • FUNDAMENTAL DISHONESTY AND CONTEMPT OF COURT: CLAIMANT BROUGHT A FRAUDULENT £3 MILLION CLAIM: SENTENCE OF IMPRISONMENT IMPOSED
  • SERVICE POINTS 22: AN APPLICATION WAS PROPERLY SERVED WHEN IT WAS SENT BY FIRST CLASS "SIGNED FOR SERVICE": THE FACT THAT THE RECIPIENT DID NOT COLLECT IT IS NOT RELEVANT
  • COST BITES 309: ISSUES OF SECURITY FOR COSTS CONSIDERED IN A SOLICITOR AND OWN CLIENT ASSESSMENT : WITH IMPORTANT POINTERS HERE FOR ALL SECURITY FOR COSTS APPLICATIONS: "I AM NOT PREPARED TO DECIDE THIS APPLICATION ON THE BASIS OF INFERENCE AND CONJECTURE")

Archives

Blogroll

  • Coronavirus: Guidance for lawyers and businesses
  • Fatal Accident Law
  • 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 National Archives Recently Published Judgments
  • The Senior Court Costs Office Guide 2025
  • Website of 4 – 5 Gray's Inn Square
  • 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 © 2025 Civil Litigation Brief

Powered by Big Yellow Workshop

 

Loading Comments...
 

You must be logged in to post a comment.