Rudan Business Holding SA v Tridan Trusted Advisors AG & Ors (Re Leo Services Holding Ltd) [2025] EWHC 3565 (Ch) (17 February 2026)

Rudan Business Holding SA v Tridan Trusted Advisors AG & Ors (Re Leo Services Holding Ltd) [2025] EWHC 3565 (Ch) (17 February 2026)

Significant developments justifying budget variations include non-consequential amendments to statements of case, expanded disclosure, increased trial length, and new issues. Parties must act promptly in submitting variations. Increases based solely on fee rate changes, redistribution of work, or overspend are not significant developments and are not approved. Variations for phases where significant developments occurred are allowed; others are disallowed.

Citation
[2025] EWHC 3565 (Ch)
Parties
Petitioner: Rudan Business Holding S. A; First Respondent: Tridan Trusted Advisors AG; Second Respondent: Daniel Tribaldos; Third Respondent: Leo Services Holding Limited
Jurisdiction
England and Wales
Judgment Date
17 February 2026
Procedural Posture
Company Law Petition Under S.994 Companies Act 2006 / Costs Management Hearing Post Amendment and Disclosure
Outcome
Variations to costs budgets allowed only for phases where significant developments occurred; other variations disallowed.
Legal Topics
Costs Management, Budget Variation, Unfair Prejudice, Disclosure, Case Management
Company Law Civil Procedure Insolvency Costs Management Budget Variation Unfair Prejudice Disclosure Case Management

Case Brief

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Parties

Rudan Business Holding S. A

Petitioner

Tridan Trusted Advisors AG

First Respondent

Daniel Tribaldos

Second Respondent

Leo Services Holding Limited

Third Respondent

Procedural Posture

Company Law Petition Under S.994 Companies Act 2006 / Costs Management Hearing Post Amendment and Disclosure

Legal Issues

  1. 1 Whether significant developments in litigation warrant revision of costs budgets under CPR 3.15A
  2. 2 Whether parties acted promptly in submitting variations
  3. 3 Whether increases in costs for various litigation phases are justified

Ratio Decidendi

Significant developments justifying budget variations include non-consequential amendments to statements of case, expanded disclosure, increased trial length, and new issues. Parties must act promptly in submitting variations. Increases based solely on fee rate changes, redistribution of work, or overspend are not significant developments and are not approved. Variations for phases where significant developments occurred are allowed; others are disallowed.

Court Disposition

Variations to costs budgets allowed only for phases where significant developments occurred; other variations disallowed.

Orders

  • Petitioner and Respondents' costs budgets revised for Issue/SOC, Disclosure, Witness statements, Trial preparation, and Trial phases.
  • Variations for expert evidence, PTR, ADR, and contingent costs disallowed.