Munemo, R. v [2023] EWHC 1636 (SCCO) (27 June 2023)

Munemo, R. v [2023] EWHC 1636 (SCCO) (27 June 2023)

Given the central importance of the image data and the laborious process required to review it in the format served, the entire body of spreadsheet entries giving access to image data should be included within the PPE count. The Determining Officer's limitation was inappropriate in this case.

Citation
[2023] EWHC 1636 (SCCO)
Parties
Respondent: R; Defendant: Munemo; Appellant's Solicitors: Bhandal Law (Solicitors)
Jurisdiction
England and Wales
Judgment Date
27 June 2023
Procedural Posture
Costs Appeal (criminal Legal Aid) / Appeal Under Regulation 29 of the Criminal Legal Aid (remuneration) Regulations 2013
Outcome
Appeal allowed
Legal Topics
Litigators' Graduated Fee Scheme, Pages of Prosecution Evidence (ppe), Electronic Evidence, Legal Aid Remuneration, Determination of Costs
Criminal Law Legal Costs Litigators' Graduated Fee Scheme Pages of Prosecution Evidence (ppe) Electronic Evidence Legal Aid Remuneration Determination of Costs

Case Brief

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Parties

R

Respondent

Munemo

Defendant

Bhandal Law (Solicitors)

Appellant's Solicitors

Procedural Posture

Costs Appeal (criminal Legal Aid) / Appeal Under Regulation 29 of the Criminal Legal Aid (remuneration) Regulations 2013

Legal Issues

  1. 1 Whether the Determining Officer erred in limiting the PPE count for electronic evidence served in spreadsheet format, particularly regarding image data, under the Criminal Legal Aid (Remuneration) Regulations 2013.

Ratio Decidendi

Given the central importance of the image data and the laborious process required to review it in the format served, the entire body of spreadsheet entries giving access to image data should be included within the PPE count. The Determining Officer's limitation was inappropriate in this case.

Court Disposition

Appeal allowed

Orders

  • The appropriate additional payment, including the £100 paid on appeal, should be made to the Applicant.
  • The PPE count is to include the entirety of the spreadsheet entries for image data, resulting in a total exceeding 10,000 pages.