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
Legal Issues
- 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 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.
Full Case Text
Judgment text and source record
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