R v Spriddell

R v Spriddell

The appeal was determined on the basis that an IFFO could be a valid comparator for reasonable remuneration, but the comparator offered by the applicant was not a good one on the facts. The proposition that payment under an IFFO could not be a valid comparator did not form part of the reasoning leading to the decision.

Parties
Respondent: R; Applicant: David Spriddell
Jurisdiction
England and Wales
Judgment Date
30 March 2026
Procedural Posture
Costs Appeal / Application for Certification of Point of Principle
Outcome
application dismissed
Legal Topics
Defendant's Costs Order, Reasonable Remuneration, Legal Aid Rates, Very High Costs Case (vhcc), IFFO Scheme
Criminal Law Costs Defendant's Costs Order Reasonable Remuneration Legal Aid Rates Very High Costs Case (vhcc) IFFO Scheme

Case Brief

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Parties

R

Respondent

David Spriddell

Applicant

Procedural Posture

Costs Appeal / Application for Certification of Point of Principle

Legal Issues

  1. 1 Whether payment under the IFFO scheme can be a valid comparator for determining reasonable remuneration under a defendant's costs order
  2. 2 Whether the court should have regard to potential fixed fees payable under the IFFO scheme when assessing reasonable remuneration

Ratio Decidendi

The appeal was determined on the basis that an IFFO could be a valid comparator for reasonable remuneration, but the comparator offered by the applicant was not a good one on the facts. The proposition that payment under an IFFO could not be a valid comparator did not form part of the reasoning leading to the decision.

Court Disposition

application dismissed

Orders

  • No certification of a Point of Principle of General Importance