Hunt v Oceania Capital Reserves Ltd & Ors [2025] EWHC 837 (Ch) (10 April 2025)

Hunt v Oceania Capital Reserves Ltd & Ors [2025] EWHC 837 (Ch) (10 April 2025)

Relief from sanctions was refused because the breach was serious and substantial: the costs budget filed was incoherent, contained incorrect figures apparently copied from the claimant's budget, and was verified by a statement of truth without genuine belief in its accuracy. The explanations for the breach were inadequate, and the revised budget did not inspire confidence. Granting relief would undermine the integrity of the budgeting process and the administration of justice.

Citation
[2025] EWHC 837 (Ch)
Parties
Claimant: Stephen Herbert Hunt; First Defendant: Oceania Capital Reserves Limited; Second Defendant: IPS Law LLP; Third Defendant: Mr Christopher William Farnell
Jurisdiction
England and Wales
Judgment Date
10 April 2025
Procedural Posture
Application for Relief From Sanctions / Post Ccmc, Determination of Relief From Sanctions Under CPR R 3.9(1)
Outcome
Application for relief from sanctions dismissed.
Legal Topics
Relief From Sanctions, Costs Budgeting, Statement of Truth, Procedural Compliance
Civil Procedure Costs Relief From Sanctions Costs Budgeting Statement of Truth Procedural Compliance

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Parties

Stephen Herbert Hunt

Claimant

Oceania Capital Reserves Limited

First Defendant

IPS Law LLP

Second Defendant

Mr Christopher William Farnell

Third Defendant

Procedural Posture

Application for Relief From Sanctions / Post Ccmc, Determination of Relief From Sanctions Under CPR R 3.9(1)

Legal Issues

  1. 1 Whether relief from sanctions should be granted for late and defective filing of costs budget under CPR r 3.13(1)
  2. 2 Whether the costs budget filed by IPS Law LLP and Mr Farnell complied with procedural requirements
  3. 3 Impact of incorrect figures and statement of truth in costs budget

Ratio Decidendi

Relief from sanctions was refused because the breach was serious and substantial: the costs budget filed was incoherent, contained incorrect figures apparently copied from the claimant's budget, and was verified by a statement of truth without genuine belief in its accuracy. The explanations for the breach were inadequate, and the revised budget did not inspire confidence. Granting relief would undermine the integrity of the budgeting process and the administration of justice.

Court Disposition

Application for relief from sanctions dismissed.

Orders

  • Second and third defendants deemed to have filed a costs budget limited to court fees under CPR r 3.14.
  • No permission to rely on revised costs budget.