XX & Anor v Jordan Young & Anor

XX & Anor v Jordan Young & Anor

Recoverable costs in a quantum only claim are limited to those reasonably incurred, excluding unjustified leading counsel fees, excessive internal communications, administrative tasks, and duplicated work. Delegation and preparation of consent forms are recoverable if not excessive. Proportionality and reasonableness are the guiding standards for assessment.

Parties
First Claimant: XX (a protected party by her husband and litigation friend YY); Second Claimant: ZZ; Defendant: Jordan Young; Defendant: Aviva Insurance Limited
Jurisdiction
England and Wales
Judgment Date
20 March 2025
Procedural Posture
Detailed Costs Assessment / Judgment on Disputed Costs Items
Outcome
Costs partly allowed, partly reduced/disallowed as per detailed assessment.
Legal Topics
Detailed Assessment, Quantum Only Claim, Recoverability of Costs, Proportionality, Delegation, Duplication, Administrative Tasks, Expert Evidence, Schedule of Loss, Conferences With Counsel

Case Brief

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Parties

XX (a protected party by her husband and litigation friend YY)

First Claimant

ZZ

Second Claimant

Jordan Young

Defendant

Aviva Insurance Limited

Defendant

Procedural Posture

Detailed Costs Assessment / Judgment on Disputed Costs Items

  1. 1 What costs are recoverable in a quantum only claim?
  2. 2 Are delegation and internal communications recoverable?
  3. 3 Is time spent on administrative tasks recoverable?

Ratio Decidendi

Recoverable costs in a quantum only claim are limited to those reasonably incurred, excluding unjustified leading counsel fees, excessive internal communications, administrative tasks, and duplicated work. Delegation and preparation of consent forms are recoverable if not excessive. Proportionality and reasonableness are the guiding standards for assessment.

Court Disposition

Costs partly allowed, partly reduced/disallowed as per detailed assessment.

Orders

  • Grade A: 125 hours allowed for documents
  • Grade B: 19.4 hours allowed for documents