Counter Schedule of special damages—multi track
Counter Schedule of special damages—multi track

The following PI & Clinical Negligence guidance note provides comprehensive and up to date legal information covering:

  • Counter Schedule of special damages—multi track
  • Section A: Past losses

STOP PRESS: Note that amendments to CPR PD 22 regarding statements of truth will come into force on 6 April 2020. The changes address the issue of cases where a witness statement is presented in English but where, notwithstanding signature of the statement, the witness cannot speak English and the statement is not necessarily ‘in their own words’. CPR PD 22 will also require a statement of truth to be dated with the date that it is signed and the required wording of the statement of truth will be amended to include a warning that proceedings for contempt of court may be brought against those who give a statement of truth without an honest belief in its truth. For more information, see News Analysis: 113th practice direction update—31 March and 6 April 2020—Changes in force 6 April 2020. This content will be updated in light of these changes in time for the 6 April 2020 in force date.

Section A: Past losses

  1. 1

    Past loss of earnings

    1. (i)–(ii) Loss of earnings to 17 June 2009 are agreed in the pleaded claim of £3,743.41.

      (iii)–(iv) Loss in the period 18 June 2009 to 15 June 2011 is not admitted. In principle, the Defendant would accept that it might take some time to obtain equally remunerative work. However,