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
Summary, issues, holding and outcome
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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
Legal Issues
- 1 What costs are recoverable in a quantum only claim?
- 2 Are delegation and internal communications recoverable?
- 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
Full Case Text
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