Woollard & Anor v Fowler

Fees charged by medical reporting agencies for obtaining medical reports and records are recoverable as disbursements under CPR 45.10 in the fixed costs regime, provided they are reasonable, proportionate, and do not include administration charges, reflecting general and established custom.

Parties: Appellant/claimant: Mr I Woollard; Appellant/claimant: Mrs D Woollard; Respondent/defendant: Mr R Fowler
Jurisdiction: England and Wales
Judgment Date: 24 May 2006
Procedural Posture: Civil Appeal / Appeal From Detailed Assessment
Outcome: appeal allowed
Legal Topics: Disbursements, Fixed Costs, Medical Agency Fees, Personal Injury, Predictable Costs Regime

Civil Procedure Costs Disbursements Fixed Costs Medical Agency Fees Personal Injury Predictable Costs Regime

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 4 Authorities cited 16 Party arguments 2 Amounts and remedies 11

Parties

Mr I Woollard

Appellant/claimant

Mrs D Woollard

Appellant/claimant

Mr R Fowler

Respondent/defendant

Procedural Posture

Civil Appeal / Appeal From Detailed Assessment

Legal Issues

1 Whether fees charged by a medical reporting agency for obtaining medical reports and records are recoverable as disbursements under CPR 45.10 in the fixed costs regime

Ratio Decidendi

Court Disposition

appeal allowed

Orders

Medical agency fees for obtaining medical reports and records are recoverable as disbursements under CPR 45.10.
Detailed assessment to allow recovery of reasonable and proportionate agency fees, excluding administration charges.