National House-Building Council v Hodson Developments Ltd & Ors [2025] EWHC 3438 (TCC) (15 September 2025)

National House-Building Council v Hodson Developments Ltd & Ors [2025] EWHC 3438 (TCC) (15 September 2025)

The breach by the first defendant in failing to file a costs budget was serious and significant, with no good reason for the default. The inconvenience to the court and other parties, and the lack of engagement by the first defendant, outweigh any minor credit for lack of intentionality. Maintenance of the sanction is not manifestly unjust or disproportionate. Relief from sanction is refused and the CPR 3.14 sanction remains in place.

Citation
[2025] EWHC 3438 (TCC)
Parties
Claimant: National House-Building Council; First Defendant: Hodson Developments Ltd; Second Defendant: D2 (Director of D1); Third Defendant: D3 (Former Director of D1)
Jurisdiction
England and Wales
Judgment Date
15 September 2025
Procedural Posture
Application for Relief From Sanction / Post Case Management Conference, Application Hearing
Outcome
Application for relief from sanction refused
Legal Topics
Relief From Sanctions, Costs Budgeting, CPR 3.14, Case Management
Civil Procedure Construction Law Relief From Sanctions Costs Budgeting CPR 3.14 Case Management

Case Brief

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Parties

National House-Building Council

Claimant

Hodson Developments Ltd

First Defendant

D2 (Director of D1)

Second Defendant

D3 (Former Director of D1)

Third Defendant

Procedural Posture

Application for Relief From Sanction / Post Case Management Conference, Application Hearing

Legal Issues

  1. 1 Whether the first defendant should be granted relief from the sanction imposed by CPR 3.14 for failure to file a costs budget on time

Ratio Decidendi

The breach by the first defendant in failing to file a costs budget was serious and significant, with no good reason for the default. The inconvenience to the court and other parties, and the lack of engagement by the first defendant, outweigh any minor credit for lack of intentionality. Maintenance of the sanction is not manifestly unjust or disproportionate. Relief from sanction is refused and the CPR 3.14 sanction remains in place.

Court Disposition

Application for relief from sanction refused

Orders

  • Sanction imposed by CPR 3.14 remains in place; first defendant treated as having filed a budget comprising only applicable court fees for future costs.