25 January 2007
Ultraframe (UK) Ltd and Others v Fielding [2006] EWCA Civ 1660, [2006] All ER (D) 81 (Dec)
Where dishonest conduct is being reflected in a costs order made by the trial judge, it should be made clear whether the order is made on the basis that, on the assessment, the paying party will still be entitled to raise the dishonesty in arguing that costs incurred in supporting the particular dishonesty were unreasonably incurred.
