Sharp v Blank & Ors

Sharp v Blank & Ors

The court has jurisdiction under PD3E 7.6 to revise a costs budget retrospectively, taking the last approved or agreed budget as the base reference point. Costs incurred since that date relating to significant developments are placed in the estimated columns of the revised budget. Significant developments must be...

Source-derived case information.

Parties
Claimants: John Michael Sharp (and the claimants listed in the group litigation register); Defendant: Sir Maurice Victor Blank; Defendant: John Eric Daniels; Defendant: Timothy Tookey; Defendant: Helen Weir; Defendant: George Truett Tate; Defendant: Lloyds Banking Group PLC
Jurisdiction
England and Wales
Judgment Date
21 December 2017
Procedural Posture
Group Litigation / Ruling on Application to Revise Costs Budget During Trial
Outcome
Application granted in part
Legal Topics
Costs Budgeting, Significant Developments, Revision of Costs Budgets, Practice Direction 3 E, CPR Part 3
Civil Procedure Costs Management Costs Budgeting Significant Developments Revision of Costs Budgets Practice Direction 3 E CPR Part 3

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Parties

John Michael Sharp (and the claimants listed in the group litigation register)

Claimants

Sir Maurice Victor Blank

Defendant

John Eric Daniels

Defendant

Timothy Tookey

Defendant

Helen Weir

Defendant

George Truett Tate

Defendant

Lloyds Banking Group PLC

Defendant

Procedural Posture

Group Litigation / Ruling on Application to Revise Costs Budget During Trial

Legal Issues

  1. 1 Whether the court has jurisdiction to revise costs budgets retrospectively under PD3E 7.6
  2. 2 What constitutes a significant development for costs budget revision
  3. 3 Whether interim applications can be significant developments under PD3E 7.6

Ratio Decidendi

The court has jurisdiction under PD3E 7.6 to revise a costs budget retrospectively, taking the last approved or agreed budget as the base reference point. Costs incurred since that date relating to significant developments are placed in the estimated columns of the revised budget. Significant developments must be assessed in context, and interim applications may also constitute significant developments. The extension to the trial timetable, additional disclosure, and new expert evidence were significant developments warranting budget revision; other items were not.

Court Disposition

Application granted in part

Orders

  • Defendants' costs budget to be revised in relation to extension of trial timetable, additional disclosure, and new expert evidence (items 1, 2, 3, 4) in specified sums.
  • No revision allowed for items 5, 6, and 7.