Costs orders—Sanderson and Bullock orders
Produced in partnership with Nevil Phillips of Quadrant Chambers
Practice notesCosts orders—Sanderson and Bullock orders
Produced in partnership with Nevil Phillips of Quadrant Chambers
Practice notesThis Practice Note provides information on Sanderson and Bullock orders. It discusses what they are, the circumstances in which they can be made and the rationale behind the making of such orders.
Sanderson and Bullock orders—what are they?
Sanderson and Bullock orders arise in circumstances where a claim (in contract or in tort) is brought against two or more separate defendants but where the claimant is only successful against one of those defendants.
The orders derive from the following decisions:
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Sanderson v Blyth Theatre Company (1903)—in which the court ordered the unsuccessful defendant to pay the successful defendant’s costs (a Sanderson order)
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Bullock v London General Omnibus Co (1907)—in which the court ordered the claimant to pay the successful defendant’s costs, but permitted the claimant to add those costs to the costs the claimant was to recover from the unsuccessful defendant (a Bullock order)
A Sanderson order is sometimes also referred to as a Bullock order (Mayer v Harte (1960)). They are closely related but are not the same.
Both
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