Cuthbert v Gare (t/a The Bowes Manor Equestrian Centre) (Supreme Court Costs Office):
A person who acts without a solicitor cannot recover as a disbursement the fees and expenses paid to a third party for work of a kind which a solicitor could have done. The limit on such a party recovering disbursements under CPR 48.6(3) requires the disbursement to be one that would have been allowed if the work had been done by a legal representative. Accordingly, a legal representative would not have needed to incur these expenses as a disbursement because it is the very work the legal representative would have been doing.
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