Ralph Hulme Gary (A Firm) v Gwillim [2002] EWHC 9034 (Costs) (22 October 2002)

Ralph Hulme Gary (A Firm) v Gwillim [2002] EWHC 9034 (Costs) (22 October 2002)

A solicitor's bill is enforceable if, considering both the bill's content and the client's knowledge, the client is able to judge whether to seek assessment; abbreviated bills may suffice if the client is well aware of the work done.

Citation
[2002] EWHC 9034 (Costs)
Parties
Claimant: Ralph Hulme Gary (A Firm); Defendant: Gwillim
Jurisdiction
England and Wales
Judgment Date
22 October 2002
Procedural Posture
Costs Assessment / Appeal
Outcome
appeal dismissed
Legal Topics
Solicitors' Bills, Enforceability of Bills, Assessment Procedure, Client Knowledge
Costs Law Solicitors' Regulation Solicitors' Bills Enforceability of Bills Assessment Procedure Client Knowledge

Case Brief

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Parties

Ralph Hulme Gary (A Firm)

Claimant

Gwillim

Defendant

Procedural Posture

Costs Assessment / Appeal

Legal Issues

  1. 1 What level of detail must a solicitor's bill contain to be enforceable against a client under the Solicitors Act 1974?
  2. 2 Can the client's own knowledge of the work done affect the enforceability of an abbreviated bill?

Ratio Decidendi

A solicitor's bill is enforceable if, considering both the bill's content and the client's knowledge, the client is able to judge whether to seek assessment; abbreviated bills may suffice if the client is well aware of the work done.

Court Disposition

appeal dismissed

Orders

  • Bills held enforceable against the client
  • No declaration of unenforceability