Laura Attersley v UK Insurance Limited

Laura Attersley v UK Insurance Limited

Where a Part 36 offer is accepted after the relevant period in an ex-Protocol claim not yet allocated to the multi-track at expiry of the relevant period, rule 36.20 applies and claimant is restricted to fixed costs; allocation to the multi-track after expiry does not retrospectively disapply fixed costs regime.

Parties
Claimant/respondent: Laura Attersley; Defendant/appellant: UK Insurance Limited
Jurisdiction
England and Wales
Judgment Date
03 April 2026
Procedural Posture
Civil Appeal / Court of Appeal Judgment
Outcome
Appeal allowed; order of HH Judge Duddridge restored.
Legal Topics
Costs, Fixed Costs, Part 36 Offers, RTA Protocol, Multi Track Allocation

Case Brief

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Parties

Laura Attersley

Claimant/respondent

UK Insurance Limited

Defendant/appellant

Procedural Posture

Civil Appeal / Court of Appeal Judgment

  1. 1 Whether the claimant is restricted to fixed costs under Part 45 or entitled to costs on the standard basis after accepting a Part 36 offer post-relevant period in a case allocated to the multi-track

Ratio Decidendi

Where a Part 36 offer is accepted after the relevant period in an ex-Protocol claim not yet allocated to the multi-track at expiry of the relevant period, rule 36.20 applies and claimant is restricted to fixed costs; allocation to the multi-track after expiry does not retrospectively disapply fixed costs regime.

Court Disposition

Appeal allowed; order of HH Judge Duddridge restored.

Orders

  • Claimant restricted to fixed costs under Part 45 Section IIIA as at expiry of relevant period.
  • No need to consider alternative ground based on Williams.