Edgar v Walsall Magistrates' Court

Edgar v Walsall Magistrates' Court

The claimant was not entitled to recover costs for time spent preparing his defence or for the purchase of Wilkinson on Road Traffic, as these were not expenses properly incurred under the relevant statutory scheme and regulations. Only certain disbursements, such as travel and stationery, are recoverable.

Parties
Claimant: David Edgar; Defendant: Walsall Magistrates' Court
Jurisdiction
England and Wales
Judgment Date
13 November 2007
Procedural Posture
Judicial Review / Judgment
Outcome
Application for judicial review refused
Legal Topics
Defendant's Costs Order, Litigant in Person Costs, Expert Witness Expenses
Criminal Law Costs Defendant's Costs Order Litigant in Person Costs Expert Witness Expenses

Case Brief

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Parties

David Edgar

Claimant

Walsall Magistrates' Court

Defendant

Procedural Posture

Judicial Review / Judgment

Legal Issues

  1. 1 Whether a litigant in person can recover costs for time spent preparing his defence in criminal proceedings
  2. 2 Whether the purchase of a legal textbook (Wilkinson on Road Traffic) is a recoverable expense under a Defendant's Costs Order

Ratio Decidendi

The claimant was not entitled to recover costs for time spent preparing his defence or for the purchase of Wilkinson on Road Traffic, as these were not expenses properly incurred under the relevant statutory scheme and regulations. Only certain disbursements, such as travel and stationery, are recoverable.

Court Disposition

Application for judicial review refused