Costs

Whether “special circumstances” justifying a detailed assessment existed for the purposes of s 70 of the Solicitors Act 1974 was a value judgment. It depended on comparing the particular case with the run of the mill case, in order to decide whether a detailed assessment in the particular case was justified despite the restrictions contained in s 70 (3).

An appeal court would not interfere with the decision of the first instance judge on whether special circumstances existed except in a strong case.