Daniels v The Commissioner of Police for the Metropolis

Daniels v The Commissioner of Police for the Metropolis

A successful defendant's refusal to negotiate or accept Part 36 offers does not, without more, amount to unreasonable conduct justifying a departure from the general rule on costs. Only unreasonable conduct may justify depriving a successful party of costs, and in this case, the defendant's conduct was not unreasonable.

Parties
Claimant/appellant: Fiona Jane Daniels; Defendant/respondent: The Commissioner of Police for the Metropolis
Jurisdiction
England and Wales
Judgment Date
20 October 2005
Procedural Posture
Civil Appeal / Appeal From Central London County Court Decision on Costs
Outcome
Appeal dismissed
Legal Topics
Costs Orders, Unreasonable Conduct, Part 36 Offers, Litigation Conduct

Case Brief

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Parties

Fiona Jane Daniels

Claimant/appellant

The Commissioner of Police for the Metropolis

Defendant/respondent

Procedural Posture

Civil Appeal / Appeal From Central London County Court Decision on Costs

  1. 1 When is it proper for a court to deprive a successful defendant of some or all of his costs?
  2. 2 Does refusal to negotiate or accept Part 36 offers justify a departure from the general rule on costs?

Ratio Decidendi

A successful defendant's refusal to negotiate or accept Part 36 offers does not, without more, amount to unreasonable conduct justifying a departure from the general rule on costs. Only unreasonable conduct may justify depriving a successful party of costs, and in this case, the defendant's conduct was not unreasonable.

Court Disposition

Appeal dismissed

Orders

  • Appeal dismissed
  • Costs to respondent of £4,500