Legal Watch: Property Risks & Coverage May 2014
Introduction The courts remain busy with applications for relief from sanctions, as the repercussions of Mitchell continue to make themselves felt. Lord Justice Jackson himself has this month overturned a High Court decision (see Hallam Estates Ltd & Michael Stainer v Baker below) which he says wrongly interpreted his own changes to the system and the feeling is that after the initial ‘panic’ post Mitchell, the storm is starting to calm. Hopefully the ‘buffer’ measure first referred to in the March issue of Legal Watch: Property Risks and Coverage and on which there is further information below, will assist. Those who read Legal Watch: Personal Injury will already have seen Geoff Owen’s article on disclosure below, which applies equally to property, risks and coverage work. Thanks go to Geoff for his article and to Christine Ferris for her article on Isaac Stoute v LTA.
Contact Us If you would like any further information on the cases or articles featured in this edition, please contact: Christine Ferris T: 0207 469 6282 E: caf@greenwoods-solicitors.com Geoff Owen T: 01908 298 216 E: gro@greenwoods-solicitors.com Marise Gellert T: 0207 469 6249 E: msg@greenwoods-solicitors.com
In This Issue: • Amendment to Civil Procedure Rules • Reasonable extensions of time should be granted • Disclosure • Erroneous service of a claim form by the court is effective service • Calculation of time • Guideline Hourly Rates • Third Parties (Rights Against Insurers) Act 2010 – Update
Amendment to Civil Procedure Rules The 73rd amendment to the CPR is due to come into effect on 5 June 2014. Among the amendments, CPR 3.8 (which deals with the court’s case management powers and provides that sanctions for failure to comply with a rule, practice direction or court order take effect unless the defaulting party has applied for relief from sanctions) is amended to provide that parties may agree, in writing, to an extension of time, up to a maximum of 28 days without an application to the court. This is what is being referred to colloquially as the ‘buffer’ measure. Currently, where a rule, practice direction or court order – (a) requires a party to do something within a specified time, and (b) specifies the consequence of failure to comply, the time for doing the act in question may not be extended by agreement between the parties. The case management of cases has been safeguarded by limiting the extension that parties can agree to 28 days and the parties may not agree such an extension in any event if the court has ordered that such an agreement cannot be made, or if any extension of time agreed puts the hearing date at risk. Consequential amendments are also to be made to Practice Directions 28 and 29, which deal with the fast and multi-track respectively.
03
Reasonable extensions of time should be granted In a case that demonstrates why the ‘buffer’ measure referred to above was introduced, the Court of Appeal has overturned a High Court decision where Lord Justice Jackson said that it was no part of his recommendations that parties should refrain from agreeing reasonable extensions of time. In (1) Hallam Estates Ltd (2) Michael Stainer v Teresa Baker
The appeal H submitted that the High Court judge was wrong to characterise its application for an extension of time as an application for relief from sanctions and that the costs judge’s decisions allowing the extension and refusing to set aside that order were case management decisions, with which the High Court judge was not entitled to interfere.
[2014] EWCA Civ 661 Hallam Estates Ltd (H) appealed against a decision reversing a costs judge’s decision to grant it an extension of time for serving points of dispute in
The decision
a detailed costs assessment, entitling the respondent, Ms
The Court of Appeal held that:
Baker (B), to a default costs certificate under CPR r.47.9(4).
(1) H’s application for an extension was made before the expiry of the time allowed for filing the points of dispute. The
Background H had brought and lost defamation proceedings against B and was ordered to pay B’s costs accordingly. B served her bill of costs eight months late. H asked B for a 21-day extension of time, six days before it was required to serve its points of dispute. B did not agree to it, so on the day H should have served its points of dispute it applied for an extension of time. The application was issued by the court the next day. The costs judge dealt with the matter ex parte and granted H the extension.
fact that the court staff did not date stamp the application until the following day was immaterial, as CPR 23.5 makes it clear that where an application must be made within a specified time, it is so made if the application notice is received by the court within that time. An application for an extension of the time to take any particular step in litigation was not an application for relief from sanctions, provided that the applicant filed his application notice before expiry of the permitted time period. That was the case even if the court dealt with the application after the expiry of the relevant period, following the case of Robert v Momentum Services
As the matter was dealt with in the absence of the parties,
Ltd [2003] EWCA Civ 299, [2003] 1 W.L.R. 1577. That
B applied, unsuccessfully, for that order to be set aside. H
remained the case following the recent civil justice reforms.
served its points of dispute within the extended time for
The Court of Appeal approved the decision in Guidezone
doing so.
Ltd, Re [2014] EWHC 1165 (Ch). On that basis, it followed
B appealed against the costs judge’s refusal to set aside his
that the costs judge was not dealing with an application for
order granting the extension. The High Court judge, allowing B’s appeal, found that H’s application for an extension of time was issued out of time and, therefore, it was seeking relief from sanctions, which the costs judge should not have granted as rules should be complied with. He set aside the costs judge’s order and therefore held that H’s points of dispute were not valid points of dispute and B was entitled
relief from sanctions, following the principles in Mitchell v News Group Newspapers Ltd [2013] EWCA Civ 1537, [2014] 1 W.L.R. 795 but with a straightforward application to extend time under CPR 3.1(2)(a).The costs judge was required to deal with the application in accordance with the recently amended overriding objective and had done so. H had made a reasonable application for an extension of time, which
to a default costs certificate under r.47.9(4). 04
did not put any future hearing dates in peril or otherwise disrupt the proceedings. On that basis, the costs judge’s decision to grant an extension was a proper exercise of his case management discretion. The Court of Appeal formed the view that B’s application to set aside was based upon the misapprehension that the costs judge had granted relief from sanction. His rejection of her application to set aside, for which he gave sensible reasons, was also a proper exercise of his case management powers. Accordingly the judge had erred in reversing that decision and should not have interfered with the costs judge’s exercise of his discretion.
“...the costs judge’s decision to grant an extension was a proper exercise of his case management discretion.” (2) When H asked B to agree an extension of time it had given sensible reasons for the request and B should have agreed. The Court of Appeal pointed to her own delays in serving her bill of costs (which was eight months late) and said that she could hardly complain about the modest extension of 21 days that was sought. The Court of Appeal referred to the fact that CPR 3.8 was to be amended imminently and that once it was parties would be able to agree a time extension of up to 28 days without reference to the court, provided
“...parties had a duty to help the court in furthering the overriding objective under CPR1.3” (3) Although the issue of whether the judge was wrong in directing that a default costs certificate be issued did not arise, the Court of Appeal addressed it in any event. It held obiter that H’s points of dispute would have become out of time once the judge reversed the costs judge’s decision to grant the extension. As a result the sanction in CPR47.9(3) would have come into operation. That provides that if a party serves points of dispute after the prescribed 21-day period, that party may not be heard further in the detailed assessment proceedings unless the court gives permission. That was the only sanction under the rules. CPR47.9(5) prevents the issue of a default costs certificate after the paying party has served its points of dispute (assuming they are served before a default costs certificate is issued) irrespective of whether they were served before or after expiry of the permitted time for service. It therefore followed that if B wished to obtain a default costs certificate, she had to file her request after expiry of the time permitted for serving the points of dispute and before the points of dispute were actually served. That did not happen in this case and the judge did not, therefore, have the power to direct that a default costs certificate be issued.
that it did not put any hearing date at risk. It also highlighted
Comment
that parties had a duty to help the court in furthering the
The Court of Appeal circumvented one possible line of
overriding objective under CPR1.3 and that included
argument that one might expect to see following the
allotting an appropriate share of the court’s resources to an
forthcoming amendment to CPR3.8, in specifically stating
individual case. Parties and their representatives would be
that legal representatives were not in breach of any duty
furthering the overriding objective and saving costs when
to their client when they agreed to a reasonable extension
they agreed to a reasonable extension of time that neither
of time which neither imperilled future hearing dates nor
imperilled future hearing dates nor otherwise disrupted
otherwise disrupted the conduct of the litigation. On the
the conduct of the litigation. The courts should not refuse,
contrary, it made the point that by avoiding the need for
and CPR r.1.1(2)(f) did not require them to refuse, to grant
a contested application they were furthering the overriding
reasonable extensions of time in such circumstances. 05
objective and also saving costs. It is likely then, that parties will be criticised unless they can provide a very good explanation as to why a 28-day extension is not granted whenever it is sought. Personal experience suggests that if you anticipate that a party will seek an extension at every stage, you should consider specifically asking that an order be made as part of the case management directions that certain (or even all) of the deadlines in the case cannot be extended by consent and that an application must be made. That may be particularly relevant in cases involving litigants in person but it must be borne in mind that the court may well take the view that what is sauce for the goose is sauce for the gander.
06
Disclosure Cases dealing with disclosure are relatively rare but then
inevitable that some mistakes might occur. The SFO could
come along in pairs. Two commercial cases on this topic
not be taken as waiving its rights in documents which might
are of wider application.
be inadvertently disclosed. Moreover, there were specific
In Tchenguiz and others v Director of the Serious Fraud Office (2014) EWHC 1102 (Comm) the claimants applied for permission to use certain documents which were said to be subject to public interest immunity and legal professional privilege in judicial review proceedings relating to the collapse of the Icelandic banks. CPR 31.20 states: “Where a party inadvertently allows a privileged document to be inspected, the party who has inspected the document may use it or its contents only with the permission of the court.” The documents in question consisted of (i) an Intelligence Unit briefing note, which made no reference to legal advice in its title, had been redacted in places and had been disclosed by a legally-qualified employee of one of the claimants; (ii)
matters in the body of the briefing note which indicated that there had been an obvious mistake in relation to its disclosure. It was not similar in any relevant sense to other documents which had been disclosed and in respect of which no privilege had been claimed.
‘…it would have been obvious to a reasonable solicitor … that a mistake had been made by its disclosure’.
a report; (iii) two emails between the defendant (SFO) and
From the contents of the report, it was clear that it had been
the Treasury Solicitor; and (iv) a PowerPoint presentation
produced for the dominant purpose of the judicial review,
prepared by the Icelandic Government, in respect of which a
and it would have been obvious to a reasonable solicitor, in
public interest certificate had been issued. The SFO claimed
the position of the legally qualified employee who reviewed
public interest immunity in respect of the latter document,
it, that a mistake had been made by its disclosure.
and legal advice privilege and litigation privilege in respect of the others. All of the documents had been disclosed inadvertently; therefore, the position was governed by CPR 31.20. It was common ground that the relevant guidelines were those set out by Clarke L.J. in Al Fayed (2002). Since it was not a case where the receiving party in fact realised that a mistake had been made, the issue was whether the mistake would have been obvious to a reasonable solicitor in the position of the reviewer. Refusing the application the High Court judge held that although the claimants were entitled to rely on the SFO’s legal team to conduct the disclosure process review properly, given the scale and complexity of that disclosure review it could not be regarded as infallible. It was almost 07
The subject line of the emails and their contents made it clear that the Treasury Solicitor was seeking instructions about an application being made in the context of the judicial review proceedings. It was therefore plain from the face of those emails that they were created for the dominant purpose of such an application. It followed that they attracted litigation privilege and that that would have been obvious to a reasonable solicitor in the position of the claimants’ solicitors. The statement in Al-Fayed that the same principles applied to public interest immunity as to legal professional privilege represented a correct statement of the law. Nevertheless, those principles recognised that the court was exercising an equitable jurisdiction and that there were no rigid rules.
That was equally true of the position under the CPR 31.20.
to his partner’s personal email address and not to her work
The fact that a public interest certificate had been issued in
email address, he had not waived his privilege in them.
respect of the PowerPoint presentation was a very potent
The second respondent argued that it was likely that the
and relevant matter to consider. It was not the case that,
claimant had emailed the documents to his partner’s work
absent obvious mistake, the court would be bound to grant
email address and that in doing so he would, or should, have
permission to use the documents; any such conclusion
known that the second respondent would have an electronic
would be contrary to the Al-Fayed principles. Since the
information policy in place meaning that his partner would
court had not been invited to consider whether the public
have no expectation of privacy in relation to the documents.
interest immunity was properly claimed, or should be overridden having regard to the private interests of the parties, the public interest certificate had to be taken at face value and given effect, without deciding whether the instant case was one of “obvious mistake”. Accordingly, the SFO was granted the relief sought and the discretion under CPR 31.20 was not exercised in the claimants’ favour.
Finding in favour of the claimant, the High Court judge held that there was no dispute that the claimant was entitled to assert privilege in respect of the relevant documents. In those circumstances the ultimate question was whether he had communicated the privileged documents to his partner in circumstances importing, expressly or impliedly, that she should treat them as confidential, in which case privilege
In the second case, Shepherd v Fox Williams LLP and others
was maintained; or whether the documents had been
(2014) EWHC 1224 (QB), the applicant/claimant applied
disclosed to her with no express or implied requirement,
for summary judgment in his claim for delivery up, and/or
that they should be treated as confidential so that there
destruction of, certain documents against the respondent/
had been a waiver, on a limited basis, of privilege. There
defendants.
was no evidence whatsoever to support the respondents’
The claimant’s partner was a former employee of the second respondent. The partner had brought employment tribunal proceedings against the second respondent. The first respondent solicitors’ firm acted for the second respondent in those proceedings and gave disclosure of several documents which related directly to the claimant’s personal affairs, including documents relating to his divorce and financial position. The second respondent, in response to the claimant’s request to explain how it had obtained those documents, said that they had been lawfully obtained during an examination of its own computer system. It was common ground at the instant hearing that the documents had been on the second respondent’s server, having been stored there as a result of the claimant’s partner viewing or opening them on her work computer during her employment with the second respondent after the claimant had emailed them to her.
assertion that the claimant, or his solicitors, had emailed the privileged documents to the partner’s work email address. Accordingly, there was no factual foundation for the respondents’ case based on waiver. Any proposition that by sending the documents to his partner’s personal email address was to be treated as having waived his privilege in relation to her employer, went too far. It would have been contrary to the interests of the administration of justice if privilege was regarded as waived in such circumstances or treated as waived generally because a privileged document was disclosed for a limited purpose by a party who plainly did not contemplate doing anything which might cause his privilege to be lost. The fact that the claimant might not be able to assert privilege against his partner did not mean that he should be taken to have waived privilege more generally or in relation to the respondents specifically. There was no evidence that the claimant had asked his partner to forward the documents to her work email address or to copy them
The claimant submitted that the documents were all subject
to her employer’s server; he had merely asked her to review
to legal advice and litigation privilege, without prejudice
and comment on them. She was aware that the documents
and highly confidential. He argued that, having sent them
were privileged, highly confidential and contained sensitive 08
personal data and she had not realised that they would be stored on the server as a result of her actions. Further, there was no evidence that the claimant had been aware of the second respondent’s electronic information policy and it was not entitled to rely on that policy to argue that privilege had been waived. Accordingly, given the highly confidential nature of the documents, the limited purpose for which they were forwarded to the claimant’s partner and the circumstances in which they were communicated by the claimant to her (which carried implied obligations of confidentiality), there was no arguable basis for contending that the claimant had waived his privilege in the relevant documents, notwithstanding that they had been found on the second respondent’s computer system. In those circumstances, the claimant’s application to strike out was well founded.
Comment These cases clearly illustrate the care that is required when handling privileged documents, particularly those held in electronic format. It is not merely the content that must be kept in mind but also the consequences of sending the material electronically to a third party.
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Erroneous service of a claim form by the court is effective service The case of Isaac Stoute (a minor by his litigation friend
solicitors. This was accepted by the defendant and both
Michael Stoute) v LTA Operations Ltd (t/a Lawn Tennis
parties proceeded, erroneously as it turned out, on the
Association) [2014] EWCA Civ 657 was a classic example
assumption that service by the court had been ineffective.
of the parties compounding a muddle largely of the court’s making. This was a purely procedural decision by the Court of Appeal so the facts are not relevant, save to the extent that the claimant alleged racial discrimination. Section 118 of the Equality Act 2010 requires that a claim be brought within six months of the act to which the claim relates.
Background
The claimant was concerned that the delay in the claim form being issued may furnish the defendant with a limitation defence. This concern was unfounded, as PD7A to CPR7 states that proceedings are started when the court issues the claim form at the request of the claimant; when that claim form, as issued, was received in the court office on a date earlier than the date on which it was issued by the court, the claim is ‘brought’, for the purpose of the Limitation Act
The background to this claim is worth considering in some
1980 and any other relevant statute, on that earlier date. In
detail, not least because it contains a catalogue of errors,
this instance, therefore, the claim form would be treated as
which have a direct bearing on the subsequent decisions
having been issued on 10 February 2012.
made. The claimant attempted to issue his claim form at
On 14 May 2012 the claimant, in the mistaken belief that
Central London County Court on 10 February 2012, when
there was a limitation issue, wrongly persuaded a court
he also submitted a letter requesting the return of the issued
clerk to amend the issue date on the claim form from 08
claim form to his solicitor for service pursuant to CPR 6.4
March 2012 to 10 February 2012. On the same date he also
(b). He was told that the claim form would have to be sent
made various amendments to the claim form, including the
to the County Court Money Claims Centre (CCMCC) in
addition of a second defendant and lodged an application
Salford for issue. This was the first error by the court, as
to extend time for service of the amended claim form to 14
the claimant was seeking a declaration and an injunction
September 2012. This application was returned as he had
as well as damages, so it was not appropriate for it to be
failed to sign the Statement of Truth and it was considered
dealt with by the CCMCC. Central London County Court
to be premature since the four-month period allowed for
accepted the claim form for onward transmission to Salford
service (based on the assumption that the court’s service
and date stamped it 10 February 2012.
was ineffective) still had some time to run. The reason given
The CCMCC wasted time on unnecessary enquiries about
for the extension sought was the administrative errors in
information that had already been supplied, required to
Salford but it later transpired that the real reason was that
support the claimant’s fee remission application, with the
the claimant was awaiting the outcome of misconduct
result that the claim form was not actually issued until
proceedings brought against him by the defendant.
8 March 2012. The court then sent the claim form to the
By the time the returned application was re-lodged on 22
defendant by post on 11 March 2012, contrary to the
June 2012 it was no longer premature but the court then lost
claimant’s written instructions to return it to his solicitors
the file! The application was not considered until 28 August
for service. The claimant informed the defendant’s solicitors
2012 when the district judge dealt with it on paper, without
that the claim form had been served by the court in error
a hearing, and granted the application extending time for
and it would be served within four months of issue by his
service to 16 November 2012, in view of the delay caused 010
by the file having been lost. The claimant served the claim
reasons cited for requiring the extension came close to
form with particulars of claim on 15 November 2012.
justifying the need for one.
The district judge’s decision
Despite the fact that more than a year had by now elapsed since the claimant’s first attempt to issue the claim form on
The defendant applied to have the extension set aside and
10 February 2012, the action had proceeded no further than
the district judge heard the application on 23 January 2013.
the service of particulars of claim.
If successful, the proceedings would have lapsed, as it was now too late to serve the claim form within the original four-month time limit. In a judgment praised by the Court of Appeal as “conspicuously clear and thoughtful” the district judge decided that it would be “far better to have a clear understanding that, in the event that the Court should serve
The defendants appealed to a circuit judge, who prolonged the matter still further by allowing the appeal, making an order that the court service had, in fact, been ineffective and dismissing the proceedings.
the Claim Form contrary to a CPR 6.4(1)(b) direction it is,
The appeal
nevertheless, good service for all purposes”.
The Court of Appeal handed down its judgment on 15 May
As a consequence of this decision the claimant had served the particulars of claim out of time since CPR7.4 (1) provides that particulars of claim must either be served with the claim
2014, allowing the appeal and reinstating the district judge’s sensible decision that service by the court was effective. The effect of that was to reinstate the claim.
form or within 14 days of service thereof. The claimant’s
The matter has only now, over two years on from the issue
amendments to the claim form had also been rendered
of the claim form, been referred to the district judge to make
ineffective since the claim form had already been served
case management directions and consider costs, which will
when they were made on 14 May 2012.
no doubt be vastly disproportionate.
In his judgment the district judge adopted the common-
The Court of Appeal made a point (as the claimant was
sense approach that unless the claim was heard so as
unrepresented) of stating explicitly that the appeal was
to determine whether or not the alleged discrimination
concerned entirely with procedural issues and the decision
had occurred, there would be a fertile ground for further
that the case must be allowed to continue implied no view
disputes and tensions to arise between the parties in future.
about the substantive merits of the case.
He therefore made orders retrospectively extending time for service of the claim form and particulars of clam to the date of actual service on 15 November 12 and permitting the claimant to proceed with the claim form, as amended, save for the addition of the new defendant. He granted the defendant permission to appeal.
Comment CPR3.10 provides that where there has been an error of procedure the error does not invalidate any step taken in the proceedings unless the court so orders. Here, it might have been better (and more cost-effective) for the parties to
In recognition that his decision involved a point upon
have treated service by the court, albeit in error, as effective
which there was no previous authority the district judge
and for a consent application to have been made to stay the
considered what order he would have made upon the basis
case, pending the outcome of the misconduct proceedings.
that the court’s service of the claim form in March had been ineffective. He found that the claimant had shown no good reason for his failure to serve the claim form by 8 July 2012 (the original four-month deadline) and neither of the two
011
Calculation of time
handed to them on a plate by parties who do not know or
“...where deemed service is later than actual service, it is the deemed service date that prevails.�
understand the rules in relation to service.
On that basis, save where parties specifically exclude it,
This can be particularly important, for example when a Part
wherever possible, service should be effected electronically.
36 offer is to be made shortly before a trial.
However, it must be borne in mind that if something is
In this post Mitchell environment in which we all now find ourselves, by far the simplest way to avoid problems and pitfalls is to ensure compliance with deadlines and court orders. Late service of documents remains one area where some opponents will try and score what are often easy points,
Putting the very specific rules in relation to service of claim forms to one side, in respect of service of all other documents, it must be remembered that the CPR draws a distinction between actual service and deemed service. A distinction is also drawn between filing and service. As can be seen from the Hallam case above, filing means delivering a document to the court so that it is received by the deadline. In Hallam although it was not issued until the following day, which was after the deadline, the application had been received by the court the previous day, prior to the expiry of the deadline. Service, however, is delivering a document to a party so that it is deemed received by the deadline.
filed electronically with the court, if it is sent after 4pm it is deemed to be filed the following day (CPR PD5B paragraph 8.4) whereas assuming an order is silent as to the time for compliance, service can be effected electronically up to 4.30pm on that business day (CPR6.26). Matters become even more complicated where there is not a specific deadline but a period for compliance, within a certain number of days, or within a window of not more than a certain number but not less than a certain number of days (for example, the requirements for filing a trial bundle). Although this can be a more practical solution on the face of it, in fact it can cause even more difficulties, with confusion as to whether weekends and bank holidays should be included (not if the period is less than five days – CPR2.8(4))
What that means in practical terms is that where deemed
or whether you exclude the day the period begins (which is
service is later than actual service, it is the deemed service
usually the date of the service of the order requiring the step
date that prevails. For example, sending something (other
in question) (CPR2.8(3)).
than a claim form) by first class post, which generally means whatever is being posted actually arrives the following day (assuming it is not a Sunday) that does not mean that it is served the following day. Service by first class post deems that it is served the second day after it was left with, delivered to or collected by the relevant service provider (provided that day is a business day, or, if not, the next business day) so the fact that it has physically arrived the day after posting is irrelevant for calculating whether something has been served in time.
012
CPR2.8 provides very helpful guidance in relation to the meaning and calculation of time within the CPR (even providing some practical examples) but surely the lesson is not to risk leaving anything to the last minute.
Guideline Hourly Rates On the subject of leaving things to the last minute, the Civil Justice Council has just announced that it is still finalising its
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