Price v MGN Ltd [2018] EWHC 3395 (QB) (16 November 2018)

Price v MGN Ltd [2018] EWHC 3395 (QB) (16 November 2018)

The claimant's costs were not reasonable or proportionate in full, particularly given the lack of prior costs budgeting and the disparity with the defendant's costs. The court reduced the claimed costs by applying lower hourly rates, limiting hours allowed, and capping counsel's fees, while allowing reasonable disbursements. The claimant is entitled to costs assessed on the standard basis, but at significantly reduced amounts.

Citation
[2018] EWHC 3395
Parties
Claimant: Sean Price; Defendant: MGN Limited
Jurisdiction
England and Wales
Judgment Date
16 November 2018
Procedural Posture
Libel Action / Costs Assessment Following Preliminary Issue Trial and Summary Judgment/strike Out Applications
Outcome
Claimant awarded costs of the applications, assessed summarily on the standard basis, but at reduced amounts as specified by the court.
Legal Topics
Libel, Costs Assessment, Preliminary Issue Trial, Case Management, Costs Budgeting
Media Law Defamation Civil Procedure Libel Costs Assessment Preliminary Issue Trial Case Management Costs Budgeting

Case Brief

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Parties

Sean Price

Claimant

MGN Limited

Defendant

Procedural Posture

Libel Action / Costs Assessment Following Preliminary Issue Trial and Summary Judgment/strike Out Applications

Legal Issues

  1. 1 Whether the claimant's claimed costs for the preliminary issue trial and related applications were reasonable and proportionate
  2. 2 Whether the absence of prior costs budgeting affected the assessment of costs

Ratio Decidendi

The claimant's costs were not reasonable or proportionate in full, particularly given the lack of prior costs budgeting and the disparity with the defendant's costs. The court reduced the claimed costs by applying lower hourly rates, limiting hours allowed, and capping counsel's fees, while allowing reasonable disbursements. The claimant is entitled to costs assessed on the standard basis, but at significantly reduced amounts.

Court Disposition

Claimant awarded costs of the applications, assessed summarily on the standard basis, but at reduced amounts as specified by the court.

Orders

  • Claimant awarded costs of the applications heard on 30 October 2018, assessed summarily on the standard basis.
  • Specific reductions applied to hourly rates, hours claimed, and counsel's fees.