- Novel Part 36 offer on hourly rates only, denied additional amount under CPR 36.17(4)(d) (White v Wincott Galliford Ltd)
- What are the practical implications of this case?
- What was the background?
- What did the court decide?
- Case details
Dispute Resolution analysis: Is it possible to make a valid Part 36 offer in respect of a solitary detail, the recoverable hourly rate, and if so what ought the consequences be if the offer is a good one? This unique point came up for determination before Deputy Master Friston who has a profound understanding of costs law. He rightly described the point as novel. The claimant sought a 10% uplift on the hourly rate pursuant to the Part 36 reward regime. While holding that the offer was Part 36 compliant and successful, the Master held that it would be unjust to grant an uplift on all of the costs when the offer only related to one component part of the overall costs sought, namely, the hourly rate. Written by Professor Dominic Regan of City Law School, London.
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