Elsevier Ltd v Munro [2014] EWHC 2728 (QB), [2014] All ER (D) 07 (Aug)
CPR 36.14(d) was introduced because, under the previous regime, the claimant was insufficiently rewarded and the defendant insufficiently penalised when the claimant had made an adequate offer. The language of the sub-paragraph directed attention to the time at which the court was deciding whether to order payment of an additional amount and that “the claim” meant the claim in respect of which the court had given the judgment which was more advantageous than the offer.
