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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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NON-SOLICITOR LITIGATION ENTITIES AND WASTED COSTS: WANT TO BE £102,000 OUT OF POCKET?

August 29, 2016 · by gexall · in Costs, Members Content, Uncategorized, Wasted Costs, Witness statements

An earlier post looked at the issues relating to litigation being conducted by an non-authorised entity.  In M A Lloyd & Son Ltd -v- PPC International Limited [2016] EWHC 2162 (QB) issues of wasted costs arose in relation to a…

ATTRITIONAL WARFARE; UNMERITORIOUS POINTS AND UNFOUNDED ALLEGATIONS OF BAD FAITH: SO MUCH (AND MORE) IN ONE JUDGMENT

August 2, 2016 · by gexall · in Applications, Assessment of Costs, Conduct, Damages, Default judgment,, Expert evidence, Experts, Members Content, Uncategorized

The judgment today of Mr Justice Edis in  Hayden -v- Maidstone & Tunbridge Wells NHS Trust makes for uncomfortable reading on the issue of the general attitude of the lawyers towards the conduct of the litigation.   In addition to…

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…

WITNESS STATEMENTS: THE LAWYER'S DUTY NOT TO MISLEAD

April 9, 2016 · by gexall · in Conduct, Members Content, Uncategorized, Witness statements

There are some important observations  by Mr Justice Leggatt in Al-Saadoon & Others -v- the Secretary of State for Defence [2016] EWHC 773 (Admin).  The case relates to witness statements and the duty of the lawyer when they know that…

IT'S ALL ABOUT THE COSTS (AND A LOT OF TROUBLE): COURT OF APPEAL CASE CONSIDERED

March 22, 2016 · by gexall · in Appeals, Assessment of Costs, Conduct, Costs, Members Content, Uncategorized

The Court of Appeal judgment today  in Patience -v- Tanner [2016] EWCA Civ 158 is a classic example of the difficulties that arise when a case is, in essence, all about the costs. It shows the danger of making, and…

WHAT IS THE POINT OF THE PORTAL? INSURERS CONTACTING CLAIMANTS DIRECTLY: STILL

March 1, 2016 · by gexall · in Applications, Conduct, Members Content, Uncategorized

I post (with his permission) a letter from Kerry Kirkbride.  It relates to the regular issue of insurers ignoring claimant solicitors and writing to claimants directly after notification on the Portal. WHAT IS THE PURPOSE OF THE PORTAL? “I am…

"NEAR MISS" RULE NO LONGER APPLICABLE: COURT OF APPEAL OVERTURNS DECISION ON COSTS

February 4, 2016 · by gexall · in Appeals, Assessment of Costs, Conduct, Costs, Members Content, Part 36, Uncategorized

In Sugar Hut Group Limited -v- AJ Insurance Services [2016] EWCA Civ 46 the Court of Appeal overturned an award of costs made against a successful party. “The Claimants’ recovery exceeded the Part 36 offer by a comfortable margin and…

WASTED COSTS ORDER MADE AGAINST SOLICITORS: COMPLIANCE WITH ORDERS, ABSENT STATEMENTS AND LATE BUNDLES

November 13, 2015 · by gexall · in Bundles, Case Management, Conduct, Costs, Members Content, Uncategorized

In F-v-M [2015] EWHC 3259 (Fam) Mr Justice Cobb made a wasted costs order against a firm of solicitors. The judgment is (and was designed to be) an object lesson in the need to comply with court directions and court…

COSTS WHERE A CLAIMANT ACCEPTS A PART 36 OFFER LATE: TWO CASES WHERE THE CLAIMANTS CAME TO GRIEF

November 9, 2015 · by gexall · in Costs, Members Content, Part 36, Uncategorized

When a claimant accepts a Part 36 offer late costs become at large.  Here we look at two cases where late acceptance of a Part 36 offer had grave consequences for a claimant.* “A claimant who pursues a claim in…

PROPORTIONALITY AND SURVIVAL FOR LITIGATORS 4: CLAIM ONLY WHAT YOU CAN PROVE

November 6, 2015 · by gexall · in Civil Procedure, Conduct, Costs, Damages, Members Content, Uncategorized

Proportionality is, mostly, about money.  The problems that proportionality causes increase  in those cases  where the sums recovered are much less than those originally sought.    The over-claiming of damages is a dangerous tactic for many reasons. Not least it…

ANOTHER CASE WHERE THERE WAS AN INVALID PART 36 OFFER; NO RESPONSE TO OFFERS TO MEDIATE AND NEITHER PARTY RECOVERED COSTS

November 4, 2015 · by gexall · in Conduct, Costs, Mediation & ADR, Members Content, Uncategorized

There is a brief report on Lawtel of the Court of Appeal decision in NJ Rickard Ltd -v- Holloway (CA 03/11/2015)*. It is an example of: (i)the importance of making a valid Part 36 offer; (ii)an example of the consequences…

YOU'RE AS BAD AS EACH OTHER: NO-ONE IS GETTING ANY COSTS: POWERFUL WORDS IN THE HIGH COURT

November 3, 2015 · by gexall · in Conduct, Costs, Members Content, Uncategorized

In GBM Minerals Engineering Consultants Limited -v- GM Minerals Holdings Limited [2015] EWHC 3091 (TCC) Mr Justice Fraser had some some strong words to say about conduct and costs, resulting in a decision that no order for costs should be…

LIQUIDATORS CLAIMED £1.1 MILLION IN COSTS: NO ORDER FOR COSTS MADE: NO ROBIN HOOD ORDER HERE

October 7, 2015 · by gexall · in Assessment of Costs, Civil Procedure, Costs, Members Content, Uncategorized

I am grateful to Anton Smith of Ashton Bond Gigg Solicitors for sending me details of the decision of Mr Registrar Jones  In Brooks & Willetts (liquidators or Robin Hood Centre Plc) -v- Armstrong 2015 EWHC 2289 (Ch) a copy…

RESPONDENT TO APPLICATION TO AMEND PLEADINGS ORDERED TO PAY COSTS BECAUSE THEY SHOULD HAVE CONSENTED

September 30, 2015 · by gexall · in Amendment, Civil Procedure, Members Content, Uncategorized

I am grateful to Tobias Haynes from Regulatory Legal solicitors for sending me details of a judgment given today in relation to the costs of amendment. This is based on Tobias’ note of the judgment which was given today (30th…

MISCONDUCT ON ASSESSMENT LEADS TO REDUCTION OF COSTS BY 50%: KERINS -V- HEART OF ENGLAND NHS FOUNDATION TRUST

August 26, 2015 · by gexall · in Assessment of Costs, Conduct, Costs, Members Content, Uncategorized

There is a report on Lawtel today of the decision of District Judge Griffith in Kerins -v- Heart of England NHS Foundation Trust (Birmingham, 31st July 2015). The claimant’s costs were reduced by 50% because of misconduct in the assessment…

"AGGRESSIVE CORRESPONDENCE" AND EFFECTIVE LITIGATION: ARE THE TWO SYNONYMOUS OR DIAMETRICALLY OPPOSED?

August 20, 2015 · by gexall · in Case Management, Civil evidence, Members Content

There is an interesting report by Chloe Smith in The Law Society Gazette “Solicitor reprimanded for email calling opponent a “plonker””.  The comments that follow that article are equally interesting with the usual mix of wry and witty observations.  The…

COSTS: THE FACT YOU CAN'T PAY MAKES NO DIFFERENCE: AN IMPORTANT LESSON FOR LITIGANTS

August 13, 2015 · by gexall · in Costs, Members Content, Uncategorized

In Bridge -v- Daley [2015] EWHC 2121 (Ch) Judge Hodge QC (sitting as a judge of the High Court) considered submissions made in relation to a losing party paying costs. THE CASE The claimant sought permission to continue a derivative…

COURT OF APPEAL OVERTURNS AWARD OF INDEMNITY COSTS

August 10, 2015 · by gexall · in Appeals, Costs, Members Content, Uncategorized

In Arcadia Group Brands Ltd -v- Visa Inc [2015] EWCA Civ 883 the Court of Appeal, dismissed an appeal on the merits,  but nevertheless overturned the judge’s order for indemnity costs. THE CASE The claimants were bringing actions for breaches…

THE CHIPS ARE DOWN FOR EXPERT WHO FAILED TO DECLARE AN INTEREST

July 31, 2015 · by gexall · in Civil evidence, Expert evidence, Members Content, Uncategorized

In The Ritz Hotel Casino Ltd -v- Al Geabury [2015] EWHC 2294(QB) Mrs Justice Simler DBE was critical of an expert who failed to declare an interest in a case. The expert had become a treating doctor. “It was no…

COSTS AND CONDUCT 3: THE COURT OF APPEAL AND ISSUE BASED COSTS ORDERS

July 30, 2015 · by gexall · in Civil Procedure, Costs, Members Content, Uncategorized

This is the third case today about the issue of costs and the conduct of proceedings. It is the most  complex, Smith & Nephew plc -v- ConvaTec Technologies Inc [2015] EWCA Civ 803. THE CASE The Court of Appeal allowed…

COSTS AND CONDUCT 2: LOSER PAYS ALL APPLIES: MOORE IS NOT LESS

July 30, 2015 · by gexall · in Civil Procedure, Costs, Members Content, Uncategorized

In The London Borough of Tower Hamlets -v- The London Borough of Bromley [2015] EWHC 2271 (Ch) Mr Justice Norris refused an application for an issue based order and made an order for costs under the general rule that the…

COSTS & CONDUCT 1: MULTIPLE PARTIES, "BULLOCK" AND "SANDERSON" ORDERS AND INDEMNITY COSTS TO THE DEFENDANTS

July 30, 2015 · by gexall · in Civil Procedure, Costs, Members Content, Uncategorized

There are several cases today where the courts have considered the issue of where costs should fall and how judicial discretion should be exercised.  The first we consider is Asghar -v- Ahmad [2015] EWHC 2234 (QB) a decision of Mr…

OUCH! THINKING OF DRAFTING A COSTS BUDGET? BEST READ THIS FIRST

July 30, 2015 · by gexall · in Costs budgeting, Members Content, Uncategorized

The judgment of Mr Justice Stuart-Smith in GSK Project Management Ltd -v- QPR Holdings Ltd [2015] EWHC 2274 (TCC) is one that needs to read by anyone involved in preparing a costs budget. To say the judge was critical of…

ISSUE BASED COSTS ORDER IN THE ADMINISTRATIVE COURT: A MATTER OF RISKS AND REWARDS

July 21, 2015 · by gexall · in Civil Procedure, Costs, Members Content

In The Queen on the application of British Academy of Songwriters, Composers and Authorts -v- the Secretary of State for Business, Innovation and Skills [2015] EWHC 2401 (Admin) Mr Justice Green made an issue based costs order. THE CASE The…

MAKING A FINDING OF FRAUD WITHOUT EVIDENCE 3: THE COURTS ARE NOT EASILY AFFRONTED

July 9, 2015 · by gexall · in Appeals, Civil evidence, Civil Procedure, Members Content

For the third time in a fortnight the courts have sent out a clear message of the dangers of  judges making findings of fraud without having all the evidence to hand. THE CASE In Alpha Rocks Solicitors -v- Alade [2015]…

COSTS: INDEMNITY COSTS; IMMEDIATE ASSESSMENT OF COSTS; SET OFF & POTENTIAL INSOLVENCY: A HIGH COURT DECISION

July 3, 2015 · by gexall · in Civil Procedure, Costs, Members Content

In Rawlinson & Hunter Trustees SA -v- ITG [2015] EWHC 1924 (Ch) Mr Justice Morgan considered issues relating to indemnity costs and whether assessment of costs ordered on an interlocutory hearing should take place forthwith. KEY POINTS Although the conduct…

EVIDENCE, COSTS AND THE CREDIBILITY OF WITNESSES: A CANADIAN VIEW

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

This blog has discussed  issues relating to the judicial approach of  the credibility  of witnesses many times.  Some judges have, shall we say, not been backward in giving their views on the “value” of the evidence of some of the…

PREVIOUS COSTS ORDERS STAND EVEN AFTER DISCONTINUANCE: A HIGH COURT DECISION

June 24, 2015 · by gexall · in Civil Procedure, Costs, Members Content

In Dar Al Arkan Real Estate Company -v- Al Refai [2015] EWHC 1793 (Comm) Mr Justice Andrew Smith considered whether discontinuance of an action should have an effect on previous costs orders. THE CASE The claimants had agreed terms of…

INCREASED COSTS AND "MYSTIFYING" PLEADINGS: A WARNING TO THOSE DRAFTING DEFENCES: IT'S GOING TO COST YOU

June 23, 2015 · by gexall · in Civil evidence, Civil Procedure, Costs, Members Content

The judgment of Mr Justice Edis in Davies -v- Forrett [2015] EWHC 1761 QB is an object lesson on the dangers of lax pleading. Denying the relevance of a conviction in a pleading led to the joinder of a number…

RELIEF FROM SANCTIONS AND COSTS IN THE ADMINISTRATIVE COURT: NO DOUBLE STANDARDS FOR THE GOVERNMENT

June 22, 2015 · by gexall · in Costs, Members Content, Relief from sanctions

In The Queen (on the application of Bhatt) -v- The Secretary of State for the Home Department [2015] EWHC 1724 (Admin) Helen Mountfield QC (sitting as a Deputy Judge) made some interesting observations in relation to the Denton principles, conduct…

COSTS, INDEMNITY COSTS AND CONDUCT WHEN CONSIDERING COSTS FOLLOWING AN ORDER FOR CROSS-EXAMINATION AT AN INTERLOCUTORY STAGE

June 14, 2015 · by gexall · in Civil Procedure, Costs, Members Content

In JSC Mezhdumarodiniy Promyshlenniy Bank -v- Pugachev [2015] EWHC 1694 (Ch) Mr Justice Hildyard considered the issue of whether a respondent to an order for cross-examination should be ordered to pay the costs of that application and whether those costs…

JUDGE SHOULD NOT HAVE MADE COSTS ORDER WHICH WIPED OUT CLAIMANT'S DAMAGES: COURT OF APPEAL DECISION TODAY

April 20, 2015 · by gexall · in Appeals, Applications, Civil evidence, Costs, Members Content

In Begum -v- Birmingham City Council [2015] EWCA Civ 386 the Court of Appeal allowed an appeal by a claimant where the decision on costs at first instance effectively deprived her of damages. THE CASE The issue is succinctly summarised…

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…

FOOTBALL, SEX, INJUNCTIONS AND MATERIAL NON-DISCLOSURE: BE CAREFUL NOT TO GET ON THE JUDGE'S OFFSIDE

March 26, 2015 · by gexall · in Applications, Civil evidence, Civil Procedure, Members Content

In YXB -v- TNO Mr Justice Warby set out the importance of full and frank disclosure on parties making an application for an ex-parte injunction.  It also reiterates the importance of claimants giving direct evidence whenever possible and the dangers…

"WALKING THE LINE": THE SRA ON BALANCING THE DUTIES OF LITIGATORS IN LITIGATION: A POTTED SUMMARY

March 23, 2015 · by gexall · in Avoiding negligence claims, Civil evidence, Civil Procedure, Members Content, Risks of litigation

For reasons that may become evident in later posts this is an apposite day to consider the duties owed by litigators. The SRA have produced “Walking the line” a consideration of the ethical duties owed by litigators. A BRIEF SUMMARY…

WHOLLY SUCCESSFUL DEFENDANT RECOVERS ONLY TWO-THIRDS OF COSTS BECAUSE OF FAILURE TO ENGAGE IN ADR

February 19, 2015 · by gexall · in Appeals, Applications, Costs, Mediation & ADR, Members Content, Witness statements

In Christian -v- The Commission of Police for the Metropolis [2015] EWHC 371 (QB) Mr Justice Turner considered the costs applications of a failure to a defendant to engage in mediation. THE CASE The claimant was unsuccessful in an action…

ANOTHER CASE WHERE INDEMNITY COSTS AWARDED – FOR PART OF THE CLAIM

February 18, 2015 · by gexall · in Applications, Civil evidence, Civil Procedure, Costs, Disclosure, Members Content

There are now several posts on this blog considering the importance of an award for costs on an indemnity basis and cases where judges have considered this issue. Another example can be found in the decision of Stephen Jourdan QC…

JOINDER OF A PARTY FOR COSTS, INDEMNITY COSTS & COMMENTS ON COSTS OUTSIDE THE COSTS BUDGET: EXCELERATE TECHNOLOGY ROUND 2

February 6, 2015 · by gexall · in Applications, Costs, Costs budgeting, Members Content

We looked earlier at the observations on costs in giving judgment in Excelerate Technology Ltd -v- Cumberbatch [2015] EWHC B1 Mercantile. A supplementary judgment on the costs issues is now available.  It contains the rationale for the matters discussed in the…

WHEN WILL INDEMNITY COSTS BE ORDERED? A HIGH COURT DECISION CONSIDERED

February 5, 2015 · by gexall · in Applications, Civil Procedure, Costs, Expert evidence, Members Content, Written advocacy

Indemnity costs now carry extra weight in that, on assessment, the court is not bound by the principle of proportionality. In Siegel -v- Pummell [2015] EWHC 195 (QB) Mr Justice Wilkie reviewed the relevant principles in relation to indemnity costs….

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