Key Facts
- •Claimant sought delivery of a statute bill of costs under Section 68 of the Solicitors Act 1974.
- •Defendant provided a bill dated September 22, 2022, detailing a success fee but lacking comprehensive cost breakdown.
- •Dispute centered on whether the provided bill complied with statutory requirements for a complete bill of costs.
- •The Court considered case law concerning the content and format of compliant statute bills, including Cobbett v Wood [1908] 2 KB 420, Boodia v Richard Slade and Co [2018] EWCA Civ 2667, Belsner v Cam Legal Services Ltd [2022] EWCA Civ 1387, and Karatysz v SGI Legal LLP [2022] EWCA Civ 1388.
Legal Principles
A statute bill of costs must be a complete bill of the fees, charges, and disbursements due.
Cobbett and Ors v Wood [1908] 2 KB 420
A complete bill doesn't necessitate a single document; it can comprise various parts if their unity is clear.
Cobbett and Ors v Wood [1908] 2 KB 420
Fees and charges can be in one document, disbursements in another.
Boodia v Richard Slade and Co [2018] EWCA Civ 2667
Statute bills should state agreed charges, intended charges, disbursements, payments received, outstanding sums, and sums demanded.
Karatysz v SGI Legal LLP [2022] EWCA Civ 1388
The requirement for a complete bill existed well before the Karatysz decision.
Judge's interpretation of case law
A solicitor must provide a compliant bill when specifically requested, regardless of whether the client could pursue a section 70 assessment.
Judge's interpretation of case law
Outcomes
Claimant's application for delivery of a final statute bill was successful.
The defendant's bill was incomplete and didn't comply with the established legal requirements for a statute bill as per the cited case law.
Claimant awarded costs for the application.
Success in the section 68 application entitles the claimant to costs under CPR 44.2.