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Updates and Commentary on Civil Procedure, by Gordon Exall, Barrister, Kings Chambers
Browse: Home » Civil evidence » Page 23

A TRIAL WITHOUT WITNESSES: THE PRACTICAL CONSEQUENCES: DUNNAGE -v- RANDALL

July 2, 2015 · by gexall · in Appeals, Civil evidence, Expert evidence, Experts, Liability, Members Content

The Court of Appeal decision today in Dunnage -v- Randall [2015] EWCA Civ 673 is one of those seminal cases that every tort law student will have to read.  Here we look at the case and the procedure. In particular…

HOW THE COURT ASSESSES WITNESSES: NOT A NUMBERS GAME

HOW THE COURT ASSESSES WITNESSES: NOT A NUMBERS GAME

June 30, 2015 · by gexall · in Civil evidence, Members Content, Witness statements

In TM -v- St George’s Healthcare NHS Trust [2015] EWHC 1866 (QB) Sir David Eady considered the judicial approach to witnesses and the burden of proof, stressing that the assessment of evidence is not a “numbers game”, THE CASE The…

SIMILAR FACT EVIDENCE IN CIVIL PROCEEDINGS: A REVIEW OF THE CASES

June 28, 2015 · by gexall · in Civil evidence, Members Content, Witness statements

In MRH -v- The County Court Sitting at Manchester [2015] EWHC 1795(Admin) considered earlier there was a tantalisingly short reference to similar fact evidence. This was not considered in detail by the Administrative Court, however it does highlight some interesting…

IF FINDINGS OF DISHONESTY ARE TO BE MADE THEN WITNESSES HAVE TO BE HEARD

June 24, 2015 · by gexall · in Civil evidence, Civil Procedure, Members Content, Witness statements

Two cases in two days have shown the difficulties that arise when findings of dishonesty are made by judges without hearing evidence. Here we look at the difficulties that arose when a judge held a trial without hearing evidence and…

CAUSATION AND EVIDENCE – A BURNING PROBLEM? IMPORTANT ISSUES FROM A BIZARRE SET OF FACTS

June 18, 2015 · by gexall · in Appeals, Civil evidence, Expert evidence, Experts, Members Content

In Graves -v- Brouwer [2015] EWCA Civ 595 the Court of Appeal carried out an extensive review of the principles and authorities relating to evidence and causation.  There is a useful discussion on the role and questioning of experts at…

IF YOU CAN'T PROVE IT YOU DON'T GET IT: CALLING EVIDENCE AT COURT TO PROVE A LOSS: A WORKING EXAMPLE

June 16, 2015 · by gexall · in Civil evidence, Civil Procedure, Members Content, Witness statements

A party claiming damages must bring evidence to court to prove the losses it claims.  This is a simple statement. However adducing evidence which actually proves the losses claimed often gives rise to difficulties in all spheres of litigation.  The…

OPINION EVIDENCE IN WITNESS STATEMENTS AND THE CASE THAT MAY HAVE SPARKED OFF THE JACKSON REFORMS: Multiplex -v- Cleveland Bridge

June 15, 2015 · by gexall · in Civil evidence, Civil Procedure, Experts, Members Content

Whilst doing some work on the problems caused when lay witnesses attempt to give expert evidence I came across the case of  Multiplex Constructions (UK) LImited -v- Cleveland Bridge UK Limited [2008] EWHC 2220(TCC). It makes interesting reading for a…

EXPERT REPORTS: TOO LONG AND NOT MUCH USE: CARE EXPERTS MUST TAKE MORE CARE

June 11, 2015 · by gexall · in Civil evidence, Expert evidence, Experts, Members Content

In the case of Harman -v- East Kent Hospitals NHS Foundation Trust [2015] EWHC 1662 (QB) Mr Justice Turner had some very clear criticisms of the expert reports. Some of the comments are of general importance. “Against the background of…

THE MEETING OF EXPERTS: CASE LAW AND GUIDANCE

June 11, 2015 · by gexall · in Civil Procedure, Credibility of experts, Expert evidence, Members Content

The case of Cintas Corp No 2 -v- Rhino Developments (2015 Ch D Newey J 10/6/2015) * reported on Lawtel today provides an interesting scenario in relation to the conduct of an expert and joint meetings. There is relatively little…

WITNESS EVIDENCE, CLINICAL NEGLIGENCE AND CLINICAL NOTES: A CASE IN POINT

June 6, 2015 · by gexall · in Civil evidence, Members Content, Witness statements

The judgment of Mr Justice Jay in FB -v- Rana & Princes Alexandra Hospital NHS Trust [2015] EWHC 1536 contains another interesting consideration of the value of witness evidence and contemporary records in a clinical negligence case.  I was recently…

EXPERTS GOING ON A FROLIC: A FAMILY LAW CASE WHERE THE EXPERT WITNESS WAS "THOROUGHLY UNHELPFUL"

June 1, 2015 · by gexall · in Civil evidence, Credibility of experts, Members Content

The conduct of experts has been considered many times on this blog.  There is an interesting example of problems caused in the context of family law in M -v- M [2015] EWFC B63.  Here we have an expert going well…

PHONE HACKING, MISSING DOCUMENTS AND THE ABSENT WITNESS: IMPORTANT ISSUES OF CIVIL EVIDENCE

June 1, 2015 · by gexall · in Civil evidence, Civil Procedure, Members Content

The issues raised in the “phone hacking” trial are well known. However Mr Justice Mann also made some important observations about civil evidence. In particular the inferences to be drawn when witnesses are not called or evidence not available. These…

GET AN INJUNCTION – PAY £27 MILLION IN DAMAGES: A POINT WORTH REMEMBERING

May 21, 2015 · by gexall · in Appeals, Civil evidence, Injunctions, Members Content

The judgment in AstraZeneca AB -v- KRKA dd Novo Mesto [2015] EWCA Civ 484 is one that should be read by anyone thinking of applying for an injunction and giving an undertaking in damages. The claimant obtained an injunction and…

APPEALS AGAINST DECISION TO ALLOW EXPERT EVIDENCE: DEFENDANTS TOLD TO GET ON THEIR BIKE

May 20, 2015 · by gexall · in Appeals, Civil evidence, Expert evidence, Members Content

Appeals against orders granting permission for parties to call expert witnesses are rare. It is worthwhile, therefore, reading the judgment of Mr Justice Green in Allen -v- Cornwall Council [2015] EWCA Civ 1461 (QB) with some care. THE CASE The…

PROOF OF FACTS: THE BASIC PRINCIPLES SUMMARISED (BORROWING FROM THE FAMILY COURTS)

May 18, 2015 · by gexall · in Civil evidence, Civil Procedure, Members Content

In a short judgment BR (Proof of Facts) [2015] EWFC 41 Mr Justice Peter Jackson provides a summary of key issues in relation to evidence. The judgment is specifically in relation fact finding in children cases. However part of the…

APPEALING ON THE JUDGE'S FINDINGS OF FACTS: A TRIAL IS NOT A DRESS REHEARSAL BUT "THE FIRST AND LAST NIGHT OF THE SHOW"

May 12, 2015 · by gexall · in Appeals, Civil evidence, Members Content

In the decision in Watson Farley and Williams -v- Ostrovizky today [2015] EWCA Civ 457 the Court of Appeal emphasised the difficulties of a party appealing findings of facts by the trial judge. “The aptness of the metaphor relating to…

"FUNDAMENTAL DISHONESTY" AND STRIKING OUT IN PERSONAL INJURY CASES: TEN KEY PROCEDURAL POINTS

May 9, 2015 · by gexall · in Applications, Civil evidence, Civil Procedure, Members Content

The rule as to “fundamental” dishonesty has attracted a lot of attraction (and a lot of heated debate). However there has been very little examination of the details of the Act and the consequent procedural implications.  There are 10 key…

AN EXPERT MUST DISCLOSE DETAILS OF PROFESSIONAL RELATIONSHIP WITH A PARTY OTHERWISE THE CONSEQUENCES CAN BE DIRE: EXP -v- BARKER

May 7, 2015 · by gexall · in Civil evidence, Credibility of experts, Experts, Members Content

The facts in relation to the Defendant’s expert witness in the case  of EXP -v- Barker [2015] EWHC 1289 (QB) are quite remarkable. The case shows the importance of an expert disclosing their history of dealing with the person on…

LETTERS OF EXPLANATION NOT GOOD ENOUGH: SOLICITOR SHOULD HAVE EXPLAINED MATTERS TO THE CLIENT: COURT OF APPEAL UPHOLD DECISION ON SOLICITOR'S NEGLIGENCE

April 28, 2015 · by gexall · in Appeals, Applications, Avoiding negligence claims, Civil evidence, Members Content, Personal Injury

In Procter -v- Raleys Solicitors [2015] EWCA Civ 400 the Court of Appeal upheld a decision at first instance that a failure to give an oral explanation to a client was negligent.  The solicitors could not simply rely on standard…

INTERIM PAYMENTS; SERIOUS INJURY; ACCOMMODATION AND EELES

April 28, 2015 · by gexall · in Civil Procedure, Damages, Expert evidence, Members Content, Statements of Case

The very first post on this blog was a review of the law relating to interim payments in personal injury cases after Eeles. This issue was raised against in the decision of Grainger -v- Cooper [2015] EWHC 1132 (QB). THE…

FAILURE TO GIVE ADEQUATE REPLIES TO PART 18 QUESTIONS LEADS TO ACTION BEING STRUCK OUT: RELIEF FROM SANCTIONS REFUSED

April 23, 2015 · by gexall · in Applications, Civil evidence, Civil Procedure, Members Content, Statements of Case

In his judgment today in Griffith -v- Gourgey [2015] EWHC 1080 (Ch) Mr Justice Simon addressed the issue of whether an action stands struck out if a party gives inadequate replies to Part 18 questions after a peremptory order has…

ANOTHER LATE WITNESS STATEMENT: RELIEF FROM SANCTIONS REFUSED

April 22, 2015 · by gexall · in Applications, Avoiding negligence claims, Civil evidence, Civil Procedure, Members Content, Relief from sanctions

There is a brief report on Lawtel of the decision of Judge Robinson in Buswell -v- Symes (QBD 20/04/2015) this involves another case where a witness statement was served late and permission to rely upon that statement was refused. *…

COURT CANNOT RE-OPEN "FINAL JUDGMENT": ISSUES RELATING TO DEFENDANT'S CAPACITY: EVESHAM --v- WERRETT CONSIDERED

COURT CANNOT RE-OPEN "FINAL JUDGMENT": ISSUES RELATING TO DEFENDANT'S CAPACITY: EVESHAM –v- WERRETT CONSIDERED

April 20, 2015 · by gexall · in Appeals, Civil evidence, Civil Procedure, Members Content, Risks of litigation

In the judgment today  in Eversham & Pershore Housing Association Ltd -v- Werrett [2015] EWHC 1060 (QB) Mr Justice Nicol held that the court could not re-open a decision because of later evidence in relation to the defendant’s capacity. THE…

WITNESS STATEMENTS AND AVOIDING JAIL: ARE YOU PROTECTING YOUR CLIENTS AND PROTECTING YOURSELF?

WITNESS STATEMENTS AND AVOIDING JAIL: ARE YOU PROTECTING YOUR CLIENTS AND PROTECTING YOURSELF?

April 19, 2015 · by gexall · in Applications, Avoiding negligence claims, Civil evidence, Civil Procedure, Members Content

In the recent case of Hughmans -v- Dunhill [2015] EWHC 716 (Ch) an interesting point arose about the drafting of a witness statement when a (former) client alleged that it had largely been drafted by her (former) solicitor. The assertion…

THE "URGENT NEED FOR COMMERCIAL PRACTITIONERS TO BRING A SENSE OF PROPORTION" TO LITIGATION: EVIDENCE NEEDED IN WHEN ARGUING SECURITY FOR COSTS "STIFLES" AN ACTION.

April 16, 2015 · by gexall · in Applications, Civil evidence, Civil Procedure, Costs, Members Content

In Kazakhstan Kagazy Plc -v- Baglan Zhunus [2015] EWHC 996 Mr Justice Walker had strong words to say, and constructive guidance to give, in relation to some aspects of commercial litigation.  The case further serves as a reminder of the…

WITNESS STATEMENTS, EXHIBITS AND NOT MAKING AN EXHIBITION OF YOURSELF: THE OFTEN IGNORED RULES ABOUT EXHIBITS TO WITNESS STATEMENTS

April 10, 2015 · by gexall · in Applications, Costs, Liability, Members Content

Your life will not be complete unless you have read a post about exhibits to witness statements. The “exhibiting” of documents is common. It is surprising how common it is for the exhibit, and the witness statement, to fail to…

PLEADING, PARTICULARITY, SUMMARY JUDGMENT AND STRIKING OUT: WAIT UNTIL AFTER DISCLOSURE

April 10, 2015 · by gexall · in Applications, Civil evidence, Civil Procedure, Members Content, Statements of Case

In Dellal -v- Dellal [2015] EWHC 907 (Fam) Mr Justice Mostyn made some important observations about the need for particularity in pleading THE CASE The claimant was bringing an action  under the Inheritance (Provision for Family and Dependants) Act 1975…

CHANGES TO THE PRE-ACTION PROTOCOLS THAT WE KNOW ABOUT: LOW VALUE ROAD TRAFFIC ACCIDENTS

April 7, 2015 · by gexall · in Civil Procedure, Costs, Damages, Expert evidence, Members Content, Personal Injury, Rule Changes, Useful links

Important changes have been made to the Pre-Action Protocols which came into force yesterday. At the moment the whereabout of the the Protocols is a mystery in that they have not been published generally. However there are some changes to…

FATAL ACCIDENT AND FATAL PLEADINGS: THE NEED TO PLEAD AND PROVE FOREIGN LAW

April 5, 2015 · by gexall · in Applications, Civil evidence, Damages, Members Content, Statements of Case

On the face of it the case of Bianco -v- Bennett [2015] EWHC 626 (QB) is simply a case about fatal accidents. I was going to discuss it solely on the Fatal Accident Blog. On close reading, however, it reveals…

LAY EVIDENCE AND EXPERT EVIDENCE IN CLINICAL NEGLIGENCE: MORE IS NOT ALWAYS BETTER

March 31, 2015 · by gexall · in Civil evidence, Expert evidence, Members Content, Personal Injury

In Wake -v- Johnson [2015] EWHC 276(QB) HH Judge Collender QC (Sitting as Judge of the High Court) conducted a critical analysis of the lay evidence and expert evidence when dismissing a clinical negligence claim against a GP.  There are…

TROUBLESOME BUNDLES YET AGAIN: MR JUSTICE EDER SPEAKS OUT ON WASTEFUL BUNDLES IN THE COMMERCIAL COURT

March 30, 2015 · by gexall · in Applications, Civil Procedure, Members Content

The question of bundles was raised by Mr Justice Eder in Taberna Europe -v- Selskabet [2015] EWHC 871 (Comm).  This is hardly a new complaint and appears across the board in all jurisdictions. (There are now 16 posts on this…

WHY YOUR WITNESS STATEMENTS SHOULD BE MADE IN CHELSEA: MAKING FIRST HAND STATEMENTS AVOIDS PENALTIES

March 28, 2015 · by gexall · in Applications, Civil evidence, Members Content

The post earlier this week in relation to the need for full disclosure on without notice injunctions also highlighted the need for first hand evidence. There are real dangers when a solicitor signs a witness statement. That principle was highlighted…

SOLICITOR FOUND TO HAVE DELIBERATELY MISLED THE COURT: BOREH -v- DJIBOUTI

March 23, 2015 · by gexall · in Applications, Civil evidence, Civil Procedure, Disclosure, Members Content

In Boreh -v- Republic of Djibouti [2015] EWHC 769 (Comm) Mr Justice Flaux made a clear and unequivocal finding that a solicitor had deliberately misled the court. This led to the setting aside of the injunction that the clients had…

DECIDING CASES ON PAPER: WOODLANDS, EVIDENCE & DECIDING CASES "ONLINE"

February 24, 2015 · by gexall · in Civil evidence, Civil Procedure, Members Content, Witness statements, Written advocacy

The decision in Woodland -v- Maxwell looked at in an earlier blog is interesting because it is one of the rare cases where the Court of Appeal carried out a (brief) analysis of the evidence in the case more than…

WITHDRAWING FROM ADMISSIONS, MISTAKES AND THE DENTON PRINCIPLES

February 16, 2015 · by gexall · in Applications, Civil evidence, Civil Procedure, Members Content, Witness statements

There is a report on Lawtel of the decision of Judge Bidder QC in Moore -v- Worcestershire Acute Hospitals NHS Trust [12/02/15].* This case demonstrates some of the difficult issues in relation to the law of withdrawing from admissions. THE…

THE MITCHELL JUDGMENT 3: WHY MR MITCHELL WASN'T TELLING LIES AND P.C. ROWLAND WAS TELLING THE TRUTH

December 6, 2014 · by gexall · in Civil evidence, Civil Procedure, Members Content, Uncategorized, Witness statements

This blog has  looked at the fact finding process in the Mitchell judgment several times already.  Here I want to look at the issue of the “truth”. This is an issue that has wider implications for those involved in the…

INDEMNITY COSTS, COSTS BUDGETING AND WITNESS STATEMENTS:INTERVIEW ON KELLIE -v- LLOYD

September 18, 2014 · by gexall · in Applications, Costs, Costs budgeting, Members Content, Useful links, Witness statements

There is a feature on the Lexis Nexis Dispute Resolution Blog where I answer questions about the implications of the judgment in Kellie and another v Wheatley & Lloyd Architects Ltd [2014] EWHC 2886 (TCC), [2014] All ER (D) 152 (Aug)…

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