PHILIP RUSSELL KING V TV3 NETWORK SERVICES LIMITED And Anor CA CA221/02

PHILIP RUSSELL KING V TV3 NETWORK SERVICES LIMITED And Anor CA CA221/02

The Court exercised its discretion and held that exceptional circumstances existed to justify a personal costs order against a legally aided appellant but that the amount should be reduced because the appellant had partial success on a negligence issue; accordingly the appellant was ordered to pay $2,500 to the...

Source-derived case information.

Citation
openlaw-58a79fe1_6864_4580_bfaf_9fc9d1f8ede6.pdf
Parties
Appellant: Philip Russell King; First Respondent: TV3 Network Services Limited; Second Respondent: Top Shelf Productions Limited
Court
Court of Appeal
Jurisdiction
New Zealand
Judgment Date
15 December 2003
Procedural Posture
Civil Appeal / Court of Appeal Costs Decision
Outcome
Costs awarded to first respondent against appellant despite legal aid, reduced due to partial success
Legal Topics
Costs Against Legally Aided Litigant, Exceptional Circumstances, Partial Success Adjustment of Costs, Costs Assessment
Civil Procedure Costs Legal Aid Tort (negligence) Costs Against Legally Aided Litigant Exceptional Circumstances Partial Success Adjustment of Costs Costs Assessment

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Parties

Philip Russell King

Appellant

TV3 Network Services Limited

First Respondent

Top Shelf Productions Limited

Second Respondent

Procedural Posture

Civil Appeal / Court of Appeal Costs Decision

  1. 1 Whether a costs order can be made personally against a legally aided appellant
  2. 2 Whether exceptional circumstances exist to justify personal liability for costs
  3. 3 Whether the appellant's partial success on negligence grounds requires tempering of the costs award

Ratio Decidendi

The Court exercised its discretion and held that exceptional circumstances existed to justify a personal costs order against a legally aided appellant but that the amount should be reduced because the appellant had partial success on a negligence issue; accordingly the appellant was ordered to pay $2,500 to the first respondent.

Court Disposition

Costs awarded to first respondent against appellant despite legal aid, reduced due to partial success

Orders

  • Appellant to pay the first respondent for its costs of and incidental to the appeal the sum of $2,500 all in.