Price v MGN Ltd

Price v MGN Ltd

The claimant is entitled to costs, but the amount claimed is disproportionate. The court summarily assesses costs by reducing hourly rates, limiting hours allowed, and capping counsel's fees, resulting in a significantly reduced award compared to the sum claimed.

Parties
Claimant: Sean Price; Defendant: MGN Limited
Jurisdiction
England and Wales
Judgment Date
16 November 2018
Procedural Posture
Civil Libel / Costs Assessment After Preliminary Issue Trial and Summary Judgment/strike Out Applications
Outcome
Claimant awarded costs, subject to summary assessment and reduction.
Legal Topics
Libel, Costs Assessment, Case Management, Preliminary Issues

Case Brief

Summary, issues, holding and outcome

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Parties

Sean Price

Claimant

MGN Limited

Defendant

Procedural Posture

Civil Libel / Costs Assessment After Preliminary Issue Trial and Summary Judgment/strike Out Applications

  1. 1 What is the reasonable and proportionate amount of costs to be awarded to the claimant following the determination of preliminary issues in a libel action?
  2. 2 Should costs be summarily assessed and if so, in what amount?

Ratio Decidendi

The claimant is entitled to costs, but the amount claimed is disproportionate. The court summarily assesses costs by reducing hourly rates, limiting hours allowed, and capping counsel's fees, resulting in a significantly reduced award compared to the sum claimed.

Court Disposition

Claimant awarded costs, subject to summary assessment and reduction.

Orders

  • Claimant awarded costs of the applications heard on 30 October 2018, assessed on the standard basis and reduced as specified in the judgment.
  • Costs to be the claimant’s if the action succeeds.