Times Media Limited v Rayner (Costs)

Times Media Limited v Rayner (Costs)

TML should pay the Trust's costs because the disclosure outcome could have been achieved by consent without a hearing, TML failed to engage in pre-hearing compromise despite opportunity, and the Trust's costs would otherwise diminish funds intended for a vulnerable child. The public interest in media reporting is outweighed in this context by the need to protect the trust fund.

Parties
Applicant: Times Media Limited; First Respondent: Angela Rayner; Second Respondent: Mark James Rayner; Third Respondent: Lucy Sarah Taylor
Jurisdiction
England and Wales
Judgment Date
11 October 2025
Procedural Posture
Disclosure Application in Family Proceedings / Costs Ruling After Disclosure Order
Outcome
Application for costs by the Trust granted in part; TML ordered to pay the Trust's costs.
Legal Topics
Disclosure of Court Documents, Costs Orders, Trust Protection, Public Interest Vs Private Interest
Family Law Media Law Trusts Disclosure of Court Documents Costs Orders Trust Protection Public Interest Vs Private Interest

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 3 Party arguments 2 Amounts and remedies 2
Sign in to unlock

Parties

Times Media Limited

Applicant

Angela Rayner

First Respondent

Mark James Rayner

Second Respondent

Lucy Sarah Taylor

Third Respondent

Procedural Posture

Disclosure Application in Family Proceedings / Costs Ruling After Disclosure Order

Legal Issues

  1. 1 Whether the applicant (TML) should pay the costs of the Trust incurred in responding to the disclosure application
  2. 2 Which costs regime applies to a non-party disclosure application in family proceedings
  3. 3 How to balance public interest in media reporting against the need to preserve trust funds for a vulnerable beneficiary

Ratio Decidendi

TML should pay the Trust's costs because the disclosure outcome could have been achieved by consent without a hearing, TML failed to engage in pre-hearing compromise despite opportunity, and the Trust's costs would otherwise diminish funds intended for a vulnerable child. The public interest in media reporting is outweighed in this context by the need to protect the trust fund.

Court Disposition

Application for costs by the Trust granted in part; TML ordered to pay the Trust's costs.

Orders

  • TML to pay the costs of the Trust summarily assessed at £8,500 plus VAT.