Pritchard Englefield (a firm) & Anor v Steinberg

The defendant, not being a practising barrister in England and Wales and having failed to provide evidence of actual financial loss, is limited to the standard litigant in person rate of £9.25 per hour for costs. The law does not permit self-certification of a higher professional rate for barristers in these circumstances.

Parties: Claimant: Pritchard Englefield (A Firm); Claimant: Michael Leslie Cohn; Defendant: Jonathan Roger Steinberg
Jurisdiction: England and Wales
Judgment Date: 27 March 2003
Procedural Posture: Costs Appeal / Appeal From Costs Officer to Costs Judge
Outcome: Appeal dismissed
Legal Topics: Litigant in Person Costs, Practising Barrister Vs Solicitor, Assessment of Costs, Financial Loss Proof

Civil Procedure Costs Litigant in Person Costs Practising Barrister Vs Solicitor Assessment of Costs Financial Loss Proof

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Parties

Pritchard Englefield (A Firm)

Claimant

Michael Leslie Cohn

Claimant

Jonathan Roger Steinberg

Defendant

Procedural Posture

Costs Appeal / Appeal From Costs Officer to Costs Judge

Legal Issues

1 Whether a non-practising barrister litigant in person can recover costs at his claimed professional hourly rate or is limited to the standard litigant in person rate
2 Whether the defendant provided sufficient evidence of actual financial loss to justify a higher rate

Ratio Decidendi

Court Disposition

Appeal dismissed

Orders

The appeal is dismissed; the defendant is limited to the litigant in person rate of £9.25 per hour.
No further costs liability arises between the parties.