In Hadley v Przybylo [2023] EWHC 1392 (KB), a complex personal injury case, Master Victoria McCloud gave a ruling on a principle of costs budgeting under the Civil Procedure Rules. She held the costs budget cannot include charges for solicitor attendance at case management meetings with medical professionals or financial and court of protection deputies, as these do not progress the court case.
The claimant contended attendance at the meetings progressed the case as they helped maintain the schedule of loss, and were usually included in the costs. The defendant argued they were no more progressive than having lawyers attend every medical treatment appointment, and were often rejected from the costs.
Master McCloud said: ‘In my judgment having a fee earner attending rehabilitation case management meetings is not progressive… and does not fall within the notion of “costs”.’
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