Ali, R. v [2024] EWHC 1699 (SCCO) (01 July 2024)

Ali, R. v [2024] EWHC 1699 (SCCO) (01 July 2024)

Where the prosecution relies on extracts from categories of electronic data, all such data in those categories should be included in the PPE count. The correct methodology for spreadsheet-based electronic evidence is to remove blank columns, use print preview, and count full pages, aiming for a sensible approximation rather than an inflated or artificially reduced count.

Citation
[2024] EWHC 1699 (SCCO)
Parties
Prosecution: Rex; Defendant: Rimon Ali
Jurisdiction
England and Wales
Judgment Date
01 July 2024
Procedural Posture
Costs Appeal (criminal Legal Aid) / Judgment on Appeal Under Regulation 29 of the Criminal Legal Aid (remuneration) Regulations 2013
Outcome
Appeal allowed in part
Legal Topics
Litigators' Graduated Fee Scheme, Pages of Prosecution Evidence (ppe), Electronic Evidence, Remuneration of Defence Solicitors
Criminal Law Legal Aid Costs Litigators' Graduated Fee Scheme Pages of Prosecution Evidence (ppe) Electronic Evidence Remuneration of Defence Solicitors

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Parties

Rex

Prosecution

Rimon Ali

Defendant

Procedural Posture

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

Legal Issues

  1. 1 What categories of electronic data should be included in the PPE count for the purposes of the Litigators' Graduated Fee Scheme?
  2. 2 What is the correct methodology for deriving a PPE page count from electronic evidence served in spreadsheet format?

Ratio Decidendi

Where the prosecution relies on extracts from categories of electronic data, all such data in those categories should be included in the PPE count. The correct methodology for spreadsheet-based electronic evidence is to remove blank columns, use print preview, and count full pages, aiming for a sensible approximation rather than an inflated or artificially reduced count.

Court Disposition

Appeal allowed in part

Orders

  • The appropriate additional payment is to be made to the Applicant based on a total PPE count of 2,023 pages.
  • The Appellant is awarded £750 (exclusive of VAT) for costs and the £100 paid on appeal.