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Updates and Commentary on Civil Procedure, by Gordon Exall, Barrister, Kings Chambers, Leeds, Manchester & Birmingham. 4-5 Gray's Inn Square, London.
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SANCTIONS CASES: SUMMARY OF ARGUMENTS THIS MORNING

June 16, 2014 · by gexall · in Appeals, Members Content, Relief from sanctions

Here is a very brief summary of the arguments considered by the Court of Appeal in the cases on sanctions this morning.   A useful summary is also being provided by @JohnHyde1982 on twitter. Lord Justices Jackson, Dyson and Voss are…

TWO DAYS LATE SERVICE OF NOTICE OF APPEAL IS A "TRIVIAL" ERROR: HIGH COURT DECISION CONSIDERED

June 14, 2014 · by gexall · in Appeals, Applications, Civil Procedure, Members Content, Relief from sanctions

In  Harrogate Borough Council -v- Secretary of State for Communities & Local Government & Zammitt [2014] EWHC 1506 (Admin) the appellant was two days late in serving a notice of appeal.  His Honour Judge Behrens (sitting as a judge of the…

“MITCHELL BITES TO PENALISE LITIGANTS WHO FAIL TO COMPLY”: EXTENSIONS OF TIME, APPEALS AND BAHO.

May 29, 2014 · by gexall · in Appeals, Applications, Members Content, Relief from sanctions

The case of Baho & Ors –v- Meerza [2014] EWCA Civ 669 is a further example of a litigant coming to grief because they failed to file an application in time and make the application for an extension of time…

SECTION 33 AND “LONG TAIL CLAIMS”: CONSTRUCTIVE KNOWLEDGE AND RELEVANCE OF DELAY BETWEEN THE BREACH AND THE DATE OF KNOWLEDGE

May 28, 2014 · by gexall · in Appeals, Limitation, Members Content

In Collins -v- Secretary of State for Business Innovation and Skills & Ors [2014] EWCA Civ 717  the Court of Appeal considered the appropriate legal test  for the date of knowledge and exercise of the section 33 discretion when an…

SETTING ASIDE A DEFAULT JUDGMENT AFTER MITCHELL: WHAT IS THE APPROPRIATE TEST?

May 21, 2014 · by gexall · in Appeals, Applications, Civil Procedure, Members Content, Relief from sanctions

There has been much discussion of whether the Mitchell principles impact upon an application have a default judgment set aside.  There are some cases that indicate that the amended CPR 3.9 should be taken into account in relation to a…

JACKSON L.J. ON AGREEING EXTENSIONS OF TIME AND DEFAULT COSTS CERTIFICATES: IMPORTANT DEVELOPMENTS

May 19, 2014 · by gexall · in Appeals, Civil Procedure, Costs, Members Content, Relief from sanctions

I have already dealt with the rules to be introduced next month in relation to the parties being able to agree extensions of time in civil proceedings. Today Jackson L.J. made it clear that it was never part of his…

SKELETON ARGUMENTS: IF YOU DON'T DO THEM PROPERLY YOU WON'T GET PAID!

May 11, 2014 · by gexall · in Appeals, Costs, Members Content, Written advocacy

The judicial review/planning law case of Secretary of State for Local Government -v-  Hopkins Development Ltd [2014] EWCA Civ 470 contains some interesting observations of general interest to civil litigators. THE SKELETON ARGUMENTS Jackson L.J. prefaced his judgment with observations…

THE CRITERIA TO BE APPLIED WHEN A PARTY MAKES AN APPLICATION AHEAD OF THE DATE OF THE BREACH: THE ROBERT CRITERIA CONSIDERED

April 29, 2014 · by gexall · in Applications, Avoiding negligence claims, Civil Procedure, Members Content, Relief from sanctions, Serving documents

In Kaneria -v- Kaneria [2014] EWHC 1165 (Ch) it was made clear that Mitchell principles did not apply in cases where an application was made prior to the date of breach.   The principles in    Robert -v- Momentum Services [2003] EWCA…

THE CONSEQUENCES OF CHARTWELL 1: JUST DON'T EVER SERVE WITNESS STATEMENTS LATE

April 19, 2014 · by gexall · in Civil evidence, Civil Procedure, Members Content, Relief from sanctions, Uncategorized, Witness statements

It is highly dangerous for litigators to view the  decision of the Court of Appeal in Chartwell -v- Fergies as any kind of step away from the Mitchell principles.  The case has already been outlined in detail in an earlier post….

CAN MITCHELL BE UTILISED IF THERE ARE SEVERAL MINOR BREACHES? UTILISE -v- CRANSTOUN CONSIDERED: LATE FILING OF COSTS BUDGETS CAUSES ANOTHER PARTY TO COME TO GRIEF

April 11, 2014 · by gexall · in Appeals, Applications, Civil Procedure, Costs budgeting, Members Content, Relief from sanctions

In Utilise -v- Cranstoun [2014] EWHC 834 (Ch) Judge Hodge QC, sitting as a judge of the High Court, considered another issue arising out of the Mitchell criteria – in essence what is the effect of two trivial breaches on…

THE APPROPRIATE CRITERIA FOR REINSTATEMENT WHEN AN ACTION IS STRUCK OUT OF COURT'S OWN MOTION: HALEY -v- SIDDIQUE CONSIDERED

April 11, 2014 · by gexall · in Appeals, Applications, Civil Procedure, Members Content, Relief from sanctions, Striking out, Uncategorized

In Haley -v- Siddique [2014] EWHC 835 (Ch) Judge Hodge Q.C., sitting as a judge of the High Court, considered issues arising from a striking out order made of the court’s own motion.  His judgment states that the case provides…

COST BUDGET REQUIREMENT DOES NOT APPLY TO PART 8 CASES: A CASE IN POINT

April 10, 2014 · by gexall · in Appeals, Applications, Costs, Members Content, Relief from sanctions

There has been considerable discussion about whether the requirements to lodge a costs budget applies to Part 8 cases.  Part 8 cases are automatically allocated to the Multi Track and the requirements to lodge a budget was thought to apply….

MITCHELL PRINCIPLES APPLIED IN TAX TRIBUNAL

March 23, 2014 · by gexall · in Appeals, Civil Procedure, Members Content, Relief from sanctions

In Mr and Mrs B -v- Revenue & Customs the First Tier tribunal (tax) considered whether the Mitchell principles applied to permissions to appeal out of time in the first-tier tribunal tax chamber. “The law 42.         There is no guidance in…

DELAY IN MAKING APPLICATIONS CAN BE FATAL: SAMARA -V- MBI APPLICATION TO HAVE JUDGMENT SET ASIDE REFUSED ON GROUNDS OF DELAY

March 5, 2014 · by gexall · in Appeals, Applications, Members Content, Relief from sanctions

The case of  Samara –v- MBI & Partners EWHC 563 (QB) considers whether the “Mitchell” criteria is relevant to applications to have judgment set aside. THE FACTS The claimant entered judgment in default. It was more than a year later, after…

ANOTHER HIGH COURT DECISION: RELIEF FROM SANCTIONS REFUSED: CLARKE –V- BARCLAYS BANK CONSIDERED

March 3, 2014 · by gexall · in Applications, Civil Procedure, Expert evidence, Members Content, Relief from sanctions

The Clarke –v- Barclays Bank [2014] EWHC decision is interesting for a number of reasons. Among other things it provides object lessons in the dangers of failing to make prompt applications and assuming cases will settle. It also highlights the…

RELIEF FROM SANCTIONS GRANTED: DID THE COURT OF APPEAL TURN A BLIND EYE TO MITCHELL? NELSON -v- CIRCLE CONSIDERED

February 19, 2014 · by gexall · in Appeals, Applications, Civil Procedure, Members Content, Relief from sanctions

It is unusual to see the Court of Appeal granting relief from sanctions without reference to CPR 3.9 or the decision in Mitchell. That is precisely what happened in Nelson –v- Circle Thirty Three Housing Trust Ltd [2014] EWCA Civ…

MITCHELL IN THE CONTEXT OF A TAX APPEAL: HMRC HIT A STONE WALL.

February 9, 2014 · by gexall · in Appeals, Civil Procedure, Members Content, Relief from sanctions

As previous posts have shown the Mitchell criteria are being considered in wider contexts.  In R&CC –v- McCarthy & Stone (Developments) Limited the Upper Tribunal (Finance and Tax) applied it to the government’s application to appeal a decision out of…

THE COURT DIDN’T TELL ME TO FILE PRECEDENT H! WHAT HAPPENS WHEN THE PARTIES FAIL TO FILE COSTS BUDGETS BECAUSE OF BEING MISLED BY A COURT FORM?

February 7, 2014 · by gexall · in Civil Procedure, Costs, Costs budgeting, Members Content, Relief from sanctions

The penalties for failing to file Precedent H in time are draconian.  What happens if the parties do not file Precedent H because they are misled by the court directions? In Aliasghas Porbanderwalla –v- Daybridge Ltd HH Judge Worster allowed an…

OFFERS TO SETTLE: COSTS, CONDUCT AND A WHOLE LOT MORE: REHILL –v- RIDER HOLDINGS CONSIDERED

February 1, 2014 · by gexall · in Appeals, Applications, Costs, Members Content, Risks of litigation

The case of Rehill –v- Rider Holdings  [2014] EWCA Civ  42 offers quite a few lessons for litigators and litigants. In relation to offers and filing schedules of costs and the risks of litigation for litigants and lawyers.  REHILL –v- RIDER…

SERVICE OF THE CLAIM FORM: ANOTHER EXAMPLE OF A CLAIMANT COMING TO GRIEF

January 31, 2014 · by gexall · in Applications, Avoiding negligence claims, Civil Procedure, Members Content, Service of the claim form, Striking out

Prior to the Mitchell decision the easiest way for a claimant to come to grief on a procedural issue was to make a mistake with service of the claim form.  The decision Murrills –v- Berlanda [2014] EWCA Civ 6 shows…

THE DANGERS OF NOT USING PRE-ACTION PROTOCOLS & THE PRACTICE DIRECTION TO THE FULL: A WORKING EXAMPLE OF PROBLEMS CAUSED BY PREMATURE ISSUE

January 30, 2014 · by gexall · in Appeals, Applications, Avoiding negligence claims, Civil Procedure, Costs, Members Content, Striking out

The next in the series was going to be a review of the rules and principles relating to pre-action conduct.   However Kerry Underwood has written a post that deals with this issue comprehensively and I have nothing to add.  Here we look…

TWO NEW CASES WHERE RELIEF FROM SANCTIONS REFUSED: WEBB RESOLUTIONS AND LLOYD & SONS CONSIDERED IN DETAIL

January 21, 2014 · by gexall · in Appeals, Applications, Civil Procedure, Costs, Members Content, Relief from sanctions

There were two High Court cases on relief from sanctions considered today. Both were decisions  of Mr Justice Turner Here we consider Webb Resolutions –v- E-Surv Limited  [2014] EWHC 49 (QB)and M A  Lloyd –v- PPC International Ltd [2014] EWHC…

WHAT CAN A DEFENDANT ARGUE ABOUT DAMAGES IF THE CLAIMANT HAS JUDGMENT OR THE DEFENCE HAS BEEN STRUCK OUT?

January 3, 2014 · by gexall · in Civil evidence, Civil Procedure, Damages, Liability, Members Content, Relief from sanctions, Risks of litigation

 One important aspect of the new rules about relief from sanctions is that they apply to defendants as well. A defendant who is late in adducing evidence can be debarred from calling evidence as in the Durrant case. Here we…

SURVIVING MITCHELL A PRACTITIONER’S GUIDE : 1 KNOW WHAT HAPPENED IN MITCHELL AND HOW IT COULD HAVE BEEN AVOIDED

December 10, 2013 · by gexall · in Applications, Avoiding negligence claims, Civil Procedure, Members Content, Relief from sanctions

The decision in Mitchell is already having a major impact on day to day litigation. This is the first of a series of posts which looks at the Mitchell decision and deals with the practical steps that practitioner’s must take…

TIBBLES BITES AGAIN: THE PROBLEMS OF ATTEMPTING TO VARY A COURT ORDER

December 3, 2013 · by gexall · in Civil Procedure, Members Content, Relief from sanctions

Hot on the heels of the previous post in relation to variation of court orders that a party dislikes comes another report highlighting the difficulties facing a party seeking to vary an order, Apex Global Management –v- Global Torch Ltd…

THE MITCHELL CRITERIA FOR RELIEF FROM SANCTIONS: A DETAILED EXAMINATION

November 28, 2013 · by gexall · in Avoiding negligence claims, Civil Procedure, Members Content, Relief from sanctions, Striking out

There has been much comment about the effect of the Court of Appeal decision in Mitchell on litigation and litigators.  Here we look, in considerable detail, at the guidance given in relation to relief from sanctions and associated case law….

CHANGES TO PRACTICE DIRECTIONS GOVERNING APPEALS TO THE SUPREME COURT

November 12, 2013 · by gexall · in Appeals, Civil Procedure, Members Content

Appealing to the Supreme Court is likely to an extremely rare event for most practitioners. The Supreme Court has its own specific rules. “The Supreme Court has its own Directions which replace the Civil, Criminal and Taxation Practice directions and…

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