PERSONAL INJURY NEWSLETTER JULY 2014. What a relief! Or is it?



Similar documents
BAKER. - and

DO NOT PASS GO DO NOT COLLECT $200 PERSONAL INJURY PLEADINGS IN ROAD TRAFFIC ACCIDENTS

Expert evidence. A guide for expert witnesses and their clients (Second edition)

COMMENTS ARISING FROM PRELIMINARY REPORT WITH SPECIFIC REFERENCE TO CLINICAL NEGLIGENCE LITIGATION

Pg. 01 French v Carter Lemon Camerons LLP

CIVIL JUSTICE COUNCIL THE IMPACT OF THE JACKSON REFORMS ON COSTS AND CASE MANAGEMENT

Legal Watch: Personal Injury

Open, Calderbank and Part 36 offers considerations and tactics

CFAs & ATE Policies Implications for Professional Indemnity Market

Insight from Horwich Farrelly s Large & Complex Injury Group

Costs Law Update Lamont v Burton

Legal Watch: Personal Injury

MODEL DIRECTIONS FOR CLINICAL NEGLIGENCE CASES (2012) - before Master Roberts and Master Cook

Advice Note. An overview of civil proceedings in England. Introduction

Draft Pre Action Protocol for claims for damages for mesothelioma

Employment law changes for 2014 what do they mean for your business?

Province of Alberta LIMITATIONS ACT. Revised Statutes of Alberta 2000 Chapter L-12. Current as of December 17, Office Consolidation

PRE-ACTION PROTOCOL. Re: Road Traffic Accidents and Personal Injury Claims The aims of the pre-action protocols are:

Legal Watch: Personal Injury

GADSBY WICKS SOLICITORS EXPLANATION OF LEGAL TERMS

Short Form CFA based on "APIL/PIBA 9" for personal injuries and clinical negligence claims from

The Claims and Court System Scotland

Model Order clinical negligence duty-causation-quantum outside RCJ

Before : MASTER GORDON-SAKER Between : (1) ANDREW HARRISON (2) ELAINE HARRISON. - and - BLACK HORSE LIMITED

APIL/PIBA CFA version 9, for personal injuries and clinical negligence claims, from ,

COMPLAINTS ABOUT SOLICITORS. How the Law Society of Ireland can help you. Law Society of Ireland Complaints About Solicitors 1

XXXXX XXXXX. and. LOWELL FINANCIAL LIMITED t/a RED DEBT COLLECTION SERVICES PARTICULARS OF CLAIM

Derivative claims against directors - are you at risk? Companies Act 2006

Protocol for the Instruction of Experts to give Evidence in Civil Claims

IN THE EASTERN CARIBBEAN SUPREME COURT IN THE HIGH COURT OF JUSTICE (CIVIL) DECISION

Covering Disease costs NIHL and pre-action disclosure date. Part 36 offers in multi-defendant cases and quantum in mesothelioma claims

MOTOR VEHICLE ACCIDENT CLAIMS ACT

Dispute Resolution At A Glance Guide 2. The English Civil Procedure Rules The Woolf Reforms

CIVIL JUSTICE COUNCIL (CJC) RESPONSE REDUCING THE NUMBER & COSTS OF WHIPLASH CLAIMS

Step in Proceedings: A Step Too Far?

Before : THE HONOURABLE MR JUSTICE COULSON Between : PANTELLI ASSOCIATES LIMITED.

Preliminary Considerations. This chapter will enable you to achieve the following learning outcomes from the CILEx syllabus:

IN THE HIGH COURT OF JUSTICE QUEEN S BENCH DIVISION The Royal Courts of Justice Strand London WC2A 2LL PAUL CHAMBERS.

PRACTICE GUIDE TO THE ASSESSMENT OF COSTS

Legal Watch: Personal Injury. February 2014 Issue 007

Technical claims brief

PERSONAL INJURIES BAR ASSOCIATION STANDARD TERMS AND CONDITIONS TREATED AS ANNEXED TO THE CONDITIONAL FEE AGREEMENT BETWEEN SOLICITOR AND COUNSEL

CONDITIONAL FEE AGREEMENTS GUIDANCE

LIMITATION UPDATE. 1. Recently, the Courts have been looking at three areas of limitation law and

A response by the Association of Personal Injury Lawyers March 2014

Claims Post Jackson Some Additional Information. Andrew Mckie, Barrister Clerksroom - May Telephone /

Steve Mason, Legal Services and Governance Lead. Ratified and Approved CCG Governing Body on 10 October 2013 by:

A CLIENT GUIDE TO PART 36 - OFFERS TO SETTLE

Conditional Fee Arrangements, After the Event Insurance and beyond!

A Practical Summary of the New Supreme Court Civil Rules for Clark Wilson LLP Insurance Clients

CHAPTER 43 ACTIONS OF DAMAGES FOR, OR ARISING FROM, PERSONAL INJURIES

The New CFA and DBA Regime. Simon Edwards

LEGAL GUIDE TO RECOVERING A TRADE DEBT

NEW PRACTICE DIRECTION ON NON-INJURY MOTOR ACCIDENT CLAIMS

After the Event Insurance. for Personal Injury. Litigation Advantage. Legal expenses insurance experts

When is an interest not an interest?

How To File A Judicial Review

PERSONAL INJURIES PROCEEDINGS ACT (QLD) 2002 (PIPA): SECTION 30

REPUBLIC OF SOUTH AFRICA

INSOLVENT DEFENDANTS AND CLAIMANTS. 1. Corporate bodies (limited companies or LLPs) have a separate legal identity that

EMPLOYEE GUIDE Defending a Disciplinary Allegation of Misconduct

Limitation an update on recent case law

Policy and Procedure for Claims Management

The Incorporated Law Society of Cardiff and District. Members Forum 30 January 2013 JACKSON REFORMS WHERE ARE WE NOW? Michael Imperato Simon Cradick

ARE WE DOING ENOUGH TO PROTECT PROTECTED PARTIES? LESSONS FOR PERSONAL INJURY LAWYERS FROM THE SUPREME COURT JUDGMENT IN DUNHILL V BURGIN

Factors to Consider When Handling a Long Term Disability Benefits Case. Several issues may arise in the course of a lawsuit for long term disability

Headquarters Army Legal Assistance Catterick Barracks British Forces Post Office 39

WHY YOU SHOULDN T DISCLOSE ALL MEDICAL RECORDS IN PERSONAL INJURY LITIGATION

Expert. Clear. Professional.

Your Motor Legal Protection Insurance Policy Wording

Personal Injury Accreditation Scheme

Litigation by insolvent companies:

COMMITTEE ON COURT PRACTICE AND PROCEDURE REVIEW OF PRACTICE AND PROCEDURE IN RELATION TO PERSONAL INJURIES LITIGATION

Bar Council response to the Reducing Legal Costs in Clinical Negligence Claims pre-consultation paper

NEGLIGENT SETTLEMENT ADVICE. Daniel Crowley and Leona Powell consider the Court s approach to negligent settlement advice.

JENNIFER LEE. Withdrawal of Pre- Action Admissions: Woodland v Stopford, PIBULJ (July 2011).

EMPLOYERS LIABILITY AND THE ENTERPRISE AND REGULATORY REFORM ACT 2013

The Foundation of the International Association of Defense Counsel SURVEY OF INTERNATIONAL LITIGATION PROCEDURES: A REFERENCE GUIDE

A WALK THROUGH YUKON S SMALL CLAIMS COURT

We agree that by not increasing small claims track hearing fees, the Government is ensuring access to justice is not compromised.

Advising and appearing in respect of applications concerning officeholders of companies in Administration/Liquidation

Commercial Litigation. Proposed Practice Direction On Non-Injury Motor Accident Litigation. Compliance With Pre- Action Protocol.

Appellant s notice (All appeals except small claims track appeals)

How To Amend The Civil Procedure Rules

BENTLEYS, STOKES AND LOWLESS Specialists in maritime and insurance law COLLISION UNDER ENGLISH LAW

Transcription:

PERSONAL INJURY NEWSLETTER JULY 2014 What a relief! Or is it? Since November 2013 'Mitchell' is a word which has been on everyone's lips. This article outlines the findings of the Court of Appeal in the recent decision of Chartwell Estate Agents Limited v Fergies Properties SA and Hyam Lehrer [2014] EWCA Civ 506 and considers its practical implications for those dealing with applications for relief from sanctions. THE FACTS The Claimant is a company providing estate agent services and the First Defendant is a company who owned property in Knightsbridge. The action itself related to a claim brought by the Claimant for commission allegedly due from the sale of the First Defendant's property to the value of 450,000 including VAT. Proceedings were issued by the Claimant on 8 th May 2013. A defence was served on 20 th May 2013 and a Reply on 20 th June 2013. The matter then came before Master Leslie on 17 th October 2013 for a case management conference, whereby it

was directed that witness evidence be simultaneously exchanged by 4pm on 22 nd November 2013. Following Master Leslie's order, there were continued disputes between the Claimant and First Defendants' solicitors regarding disclosure. The Claimant's solicitors maintained its position that the First Defendant's solicitors had failed to satisfy its disclosure obligations, and without full disclosure they would not be in a position to finalise their witness evidence. On 20 th November 2013, two days prior to the deadline for service, the First Defendant's solicitors wrote to the Claimant's solicitors querying whether they wished to apply for an extension of time to serve their witness evidence. On 22 nd November 2013, neither party was ready to exchange their witness evidence however neither party applied to the court for an extension of time for service. The dispute regarding disclosure continued until 16 th January 2014. On that date the First Defendant wrote to the Claimant providing further disclosure, and made express reference to CPR 32.10 and CPR 3.9 and the principles laid down in Mitchell v News Group Newspapers Limited [2013] EWCA Civ 1537. An application was made to the court by the Claimant's solicitors thereafter for an extension of time to serve the witness evidence to 10 th February 2014 and for relief from sanctions for failing to serve the witness statements on 22 nd November 2013.

THE FINDINGS At first instance, Globe J held that the failure to serve the witness evidence within the prescribed timeframe could not be categorised as trivial in the sense explained in Mitchell, and that the Claimant had failed to provide sufficiently good reasons for the default. Globe J took the view that there was no justifiable reason why the relevant application for an extension of time could not have been made prior to the specified date. Notwithstanding the above, Globe J held that relief from sanctions ought to be granted to both parties, having regard to all the circumstances of the case, in particular the fact that: both parties were in default; despite the complexity of the issues between the parties, there was no reason why the trial date, fixed in a window commencing on 29 th April 2014, could not be maintained; it would be disproportionate to deprive the Claimant of the opportunity to pursue its claim; whilst following Mitchell, proportionality and compliance with rules, orders and practice directions, were regarded as being of paramount importance in respect of CPR 3.9, it does not preclude other factors from being taken into consideration; refusing to grant relief in the circumstances would be too severe a consequence and would bring about an unjust result against the history of the case;

there would be no significant additional costs consequences if relief were granted and the costs budgets would be maintained. The Defendants appealed to the Court of Appeal, with leave granted from Levison LJ. Upon appeal, Davies LJ upheld the first instance decision of Globe J and in doing so, made the following observations: Globe J was entitled to decide the matter as he did and to find that the breach was not trivial, and that there was no good reason for the default; the rules had not been deliberately flouted by the parties, there had merely been a lack of understanding as to the application of the revised rules; Globe J was entitled to depart from the expectation that the two factors specified in CPR 3.9 will usually trump other circumstances, and to find that those two factors were outweighed by the wider circumstances in this case; the decision at first instance was sound in law and he had properly applied both CPR 3.9 and Mitchell; accordingly, there was no basis for interfering with the decision of Globe J. IMPLICATIONS This decision acts as a reminder that each case will very much turn upon its own individual facts. It reminds us that the court may be inclined to grant relief where a breach cannot be regarded as trivial and where there is no good reason for the

default, when the wider circumstances of the case warrant it. The decision also illustrates that courts will be unwilling to interfere with the case management decisions where the law has been correctly applied. Whilst at first blush this decision appears to mark a departure from the robust approach taken in Mitchell and in subsequent cases, the implications of Chartwell ought not to be overstated and the decision ought not to encourage complacency. Instead, Chartwell ought to be regarded as an exceptional case with a unique set of facts. Best practice would dictate that parties strive to meet the deadlines imposed by the courts, rules and practice directions and, if this is not possible, parties should apply, in advance of the prescribed deadline, for an extension of time, or as soon as is possible for relief from sanctions. Heather Aspinall accepts instructions in all aspects of civil and personal injury litigation. Please contact her clerks on 0161 834 7000 or at clerks@stjameschambers.com. - 68 Quay Street Manchester M3 3EJ Tel: 0161 834 7000 Website: www.stjameschambers.com