Crooks v Hendricks Lovell Ltd [2016] EWCA Civ 8, [2016] All ER (D) 100 (Jan)
The Court of Appeal allowed an appeal against an order as to costs made against the appellant in circumstances where he had beaten the offer to settle for “£18,500 net of [Compensation Recovery Unit]” that had been made to him by the respondent pursuant to CPR Pt 36. The offer had been a valid one under Pt 36, the recorder had been entitled to wait to assess costs until after the Compensation Recovery Unit had reviewed the appellant’s certificate of recoverable benefits and, on the facts, the recorder had erred in concluding that the appellant had not beaten the offer.
