Admiral Management Services Ltd v Para-Protect Europe Ltd & Ors [2002] EWHC 233 (Ch) (04 March 2002)

Admiral Management Services Ltd v Para-Protect Europe Ltd & Ors [2002] EWHC 233 (Ch) (04 March 2002)

Reasonable costs of claimant's expert employees may be recoverable as costs if the employees are truly experts and the work is of expert character, but not for ordinary fact-finding or analysis. Damages for staff time are not recoverable unless the claimant proves actual expenditure or loss of revenue; salaries paid in any event are not recoverable. The settlement order does not extend to claims for loss of revenue unless specifically pleaded and proved.

Citation
[2002] EWHC 233 (Ch)
Parties
Claimant: Admiral Management Services Limited; Defendants: Para-Protect Europe Limited and Others
Jurisdiction
England and Wales
Judgment Date
04 March 2002
Procedural Posture
Chancery Division Civil Claim / Judgment on Preliminary Issues Regarding Costs and Damages Following Settlement Order
Outcome
Preliminary issues determined; claimant may recover reasonable costs of expert employees if proven to be experts and work is expert in nature; damages for staff time not recoverable absent proof of expenditure or revenue loss; further hearing required for factual determination.
Legal Topics
Recovery of Costs for in House Experts, Damages for Staff Time Investigating Torts, Interpretation of Tomlin Orders, Confidential Information, Breach of Fiduciary Duty, Breach of Copyright
Civil Procedure Costs Intellectual Property Employment Recovery of Costs for in House Experts Damages for Staff Time Investigating Torts Interpretation of Tomlin Orders Confidential Information +2 more

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Parties

Admiral Management Services Limited

Claimant

Para-Protect Europe Limited and Others

Defendants

Procedural Posture

Chancery Division Civil Claim / Judgment on Preliminary Issues Regarding Costs and Damages Following Settlement Order

Legal Issues

  1. 1 Whether costs for work done by claimant's employees are recoverable as costs
  2. 2 Whether such costs are recoverable as damages
  3. 3 Whether in-house experts' work qualifies for costs recovery

Ratio Decidendi

Reasonable costs of claimant's expert employees may be recoverable as costs if the employees are truly experts and the work is of expert character, but not for ordinary fact-finding or analysis. Damages for staff time are not recoverable unless the claimant proves actual expenditure or loss of revenue; salaries paid in any event are not recoverable. The settlement order does not extend to claims for loss of revenue unless specifically pleaded and proved.

Court Disposition

Preliminary issues determined; claimant may recover reasonable costs of expert employees if proven to be experts and work is expert in nature; damages for staff time not recoverable absent proof of expenditure or revenue loss; further hearing required for factual determination.

Orders

  • Reasonable costs of expert employees may be included in costs order if expertise and nature of work are proven.
  • Damages for staff time not recoverable unless actual expenditure or loss of revenue is proved.