Mealing McLeod v The Common Professional Examination Board [2000] EWHC 186 (QB) (30 March 2000)
The Claimant failed to provide sufficient evidence of pecuniary loss; therefore, the standard Litigant in Person rate of £9.25 per hour applies. Some additional time was allowed for specific items, but the overall approach of the Costs Judge was correct.
Source-derived case information.
- Citation
- [2000] EWHC 186
- Parties
- Appellant: Claimant; Respondent: Defendant
- Jurisdiction
- England and Wales
- Judgment Date
- 30 March 2000
- Procedural Posture
- Costs Appeal / Appeal From Detailed Assessment
- Outcome
- Appeal allowed in part
- Legal Topics
- Costs, Litigant in Person, Detailed Assessment, Pecuniary Loss, Appeals
Source-derived case record
Summary, issues, holding and outcome
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Parties
Claimant
Appellant
Defendant
Respondent
Procedural Posture
Costs Appeal / Appeal From Detailed Assessment
Legal Issues
- 1 Whether the Costs Judge erred in restricting the Claimant to the Litigant in Person rate of £9.25 per hour
- 2 Whether the Claimant proved pecuniary loss to justify a higher hourly rate
- 3 Whether the hours allowed for various items were appropriate
Ratio Decidendi
The Claimant failed to provide sufficient evidence of pecuniary loss; therefore, the standard Litigant in Person rate of £9.25 per hour applies. Some additional time was allowed for specific items, but the overall approach of the Costs Judge was correct.
Court Disposition
Appeal allowed in part
Orders
- Certificate to be redrawn to allow additional hours and disbursements as specified under Ground 5
- Final figures to reflect corrections agreed between parties
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