R v Spriddell

R v Spriddell

Routine items in Crown Court costs claims are defined by their duration and not by the complexity of the case; such items, if identified, should be allowed the same degree of enhancement as preparation time where the case justifies enhancement. Counsel's fees must be assessed by reference to Legal Aid rates, and the Determining Officer's allowance represented reasonable remuneration in the circumstances.

Parties
Respondent: R; Appellant: David Spriddell
Jurisdiction
England and Wales
Judgment Date
02 June 2026
Procedural Posture
Criminal Costs Appeal / Appeal From Determining Officer's Assessment Under Regulation 10 of the Costs in Criminal Cases (general) Regulations 1986
Outcome
Appeal allowed in part and dismissed in part
Legal Topics
Defendant's Costs Order, Assessment of Costs, Legal Aid Rates, Enhancement of Costs, Counsel's Fees
Criminal Law Costs Defendant's Costs Order Assessment of Costs Legal Aid Rates Enhancement of Costs Counsel's Fees

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Parties

R

Respondent

David Spriddell

Appellant

Procedural Posture

Criminal Costs Appeal / Appeal From Determining Officer's Assessment Under Regulation 10 of the Costs in Criminal Cases (general) Regulations 1986

Legal Issues

  1. 1 Whether routine items should be enhanced in complex cases for Crown Court costs
  2. 2 Whether counsel's fees allowed by the Determining Officer represented reasonable remuneration by reference to Legal Aid rates

Ratio Decidendi

Routine items in Crown Court costs claims are defined by their duration and not by the complexity of the case; such items, if identified, should be allowed the same degree of enhancement as preparation time where the case justifies enhancement. Counsel's fees must be assessed by reference to Legal Aid rates, and the Determining Officer's allowance represented reasonable remuneration in the circumstances.

Court Disposition

Appeal allowed in part and dismissed in part

Orders

  • Routine items in Crown Court costs to be allowed the same degree of enhancement as preparation time
  • No further costs awarded to the Appellant beyond the £100 appeal fee