The View August qxp by sanmelody


									                                                                                                                   August 2006


       Health and safety                        R v Hatton Traffic Management Ltd
       Damages                                  Flora v Wakom (Heathrow) Ltd
       Civil Procedure                          Toth v Jarman
       Pre-action admissions                    Stoke on Trent City Council v Walley
       Costs - proportionality                  Rogers v Merthyr Tydfil County Borough Council
       Burden of proof                          Newman v Laver and another
       Limitation                               McHugh v Gray
       Quantum                                  W v Abraham ( meningococcal septicaemia)
                                                Ball v Belfield (index finger)
                                                Priest v Liverpool City Council (knee and ankle)
                                                Boyd v Hovey (knee, rib and spleen)

News watch                                      following her successful claim for bullying   Expert witness immunity
                                                in the workplace. She claimed she was
                                                victimised by colleagues and suffered a       The Court of Appeal has reserved judgment
Compensation Act 2006                           nervous breakdown as a result. The            on an appeal by the General Medical
                                                bank denied any breach of statutory duty,     Council against the decision of the High
Spring 2007 should herald the introduction      alleging that the claimant was vulnerable     Court that an expert witness has immunity
of a new, stricter regime for claims            to mental illness. The judge held that she    from suit in respect of evidence given in a
management companies following the              was a victim of a deliberate and              court of law. The case centred on the
giving of Royal Assent to the                   concerted campaign of bullying that           evidence given by Professor Roy Meadows
Compensation Bill on 25 July 2006. The          caused her breakdown. The award               who was struck off the GMC medical
Act also provides for the speeding up of        included £35,000 for pain, suffering and      register in July 2005 for misconduct following
the recovery of compensation by                 loss of amenity, £25,000 for loss of          the discrediting of figures put forward by the
mesothelioma victims and enables the            mobility on the labour market, £116,000       Professor as to the chances of two
court to take into account the possible         for past losses and £640,000 for future       unexplained infant deaths occurring in one
deterrent effect of a finding of potential      losses.                                       family. The High Court said that the
liability. The Act promotes a less                                                            Professor had immunity from suit and
adversarial approach to personal injury                                                       should not have been pursued by the GMC.
litigation and specifically provides that the   Late admission
giving of an apology, or an offer of
treatment or other redress, does not of         Swansea NHS Trust has finally admitted        MoD tests
itself amount to an admission of                liability for the death of a woman some
negligence or breach of statutory duty.         five years after the incident. The woman      Some 300 Porton Down veterans are now
The Act can be viewed at:                       bled to death when her uterus ruptured        preparing to issue proceedings against the         after giving birth to her stillborn child.    MoD claiming damages for injury as a
060029.htm                                      The consultant obstetrician who was           result of chemical testing at the biological
                                                called by hospital staff to confirm their     defence establishment from 1939 to 1989.
Bullies at the bank                             plan that the baby should be delivered        Hopes of settlement were prompted by the
                                                naturally at eight and a half months had      out of court settlement and acceptance of
City worker Helen Green was awarded             declined to attend. A settlement of           charges of manslaughter by the MoD
over £800,000 against her former                £300,000 was agreed upon.                     earlier this year with the family of Ronald
employers, Deutsche Bank Group,                                                               Maddison, who died after taking part in a
                                                                                              Sarin gas experiment in 1953.
Health and safety - criminal liability;         Hatton interpreted the meaning of 'so far          The claimant should be allowed to
safe system of work                             as is reasonably practicable' contained            advance his statement of case to trial
                                                within s2(1) of HSWA as one element of             and it was for the trial judge to decide
R v Hatton Traffic Management Ltd               the employer's overall duty rather than a          whether to invoke his power under s2(9).
[2006] EWCA 1156                                defence so that the employer was not
Court of Appeal - Latham LJ                     precluded by Regulation 21 from                    Robert Glancy QC and Robert Weir for
June 2006                                       demonstrating that it had taken all                the claimant
                                                reasonably practicable steps.                      Michael Pooles QC and Oliver Ticciati for
The defendant company was responsible           Employers will as a consequence be                 the defendant
for providing traffic services and              able to argue in circumstances of default
equipment to contractors engaged in             by their employee that they took all
resurfacing the A66. Two employees of           reasonable health and safety precautions           Civil procedure - expert witnesses;
the defendant were killed when equipment        and discharged their statutory duties.             conflict of interest
they were moving for resurfacing work
came into contact with high voltage                                                                Toth v Jarman [2006]
overhead cables. The defendant was              Damages - loss of earnings; future                 Court of Appeal - Sir Mark Potter, Arden
prosecuted for breach of s2(1) of the           care needs; s2 Damages Act 1996                    and Wall LJJ
Health and Safety at Work Act 1974 which                                                           19 July 2006
provides that, 'It shall be the duty of every   Flora v Wakom (Heathrow) Ltd [2006]
employer to ensure, so far as is reasonably     EWCA Civ 1103                                      The claimant sought damages for
practicable, the health, and safety at work     Court of Appeal - Sir Mark Potter, Brooke          nervous shock and psychiatric injury
of all his employees'. The defendant            and Moore-Bick LJJ                                 following the death of his five-year-old
wished to call evidence at trial that it had    28 July 2006                                       son, Wilfred, in circumstances in which
taken all reasonably practicable steps to                                                          he alleged the defendant GP was
ensure the safety of its employees, that        The defendant appealed the decision of             negligent. Wilfred suffered from glycogen
the accident was a result of their own          Sir Michael Turner dismissing its                  storage disease and was drip fed
actions and that it was not foreseeable         application to strike out the parts of the         glucose during the night, without which
that the employees would act in the way         claimant's statement of case as to the             he would become hypoglycaemic. The
they did such that it would be necessary        application of s2(9) of the Damages Act            drip had not worked one night and the
for the defendant to take further               1996, which was introduced by the                  defendant was called to the house to
precautions. The judge ruled in favour of       Courts Act 2003. (See March 2006 issue             give emergency treatment. The
the defendant and the HSE appealed.             of The View.) The claimant alleged that a          defendant administered suppositories
                                                wage-related index would be more                   which reduced Wilfred's hypoglycaemic
The issues were whether evidence of             appropriate than the retail prices index           fit and arranged for transfer to hospital.
foreseeability was irrelevant in the case       as the mechanism for varying the sums              No intravenous glucose injection was
and whether Regulation 21 of the                payable under the periodical payments              administered until Wilfred reached
Management of Health and Safety at              order and the court had the power under            hospital, about an hour later. He never
Work Regulations 1999 precluded the             s2(8) to make such an order. The                   recovered consciousness and died the
company from relying on any act or              defendant argued that s2(8) contained              next week. The judge held that the
default of its employee in its defence.         the order the court should ordinarily              failure to administer an intravenous
                                                make and s2(9) would only be triggered             injection was negligent but, on the expert
Whilst the notion of foreseeability is an       by exceptional circumstances. It argued            evidence of two distinguished specialists,
element in determining civil liability it is    that the legislation was ambiguous and             Professors Hull and Marks, he was not
not an element in determining criminal          consideration should be given to debate            satisfied that had the injection been
liability under health and safety               and reports at the Bill stage.                     administered timeously, the son would
legislation. However, the Court of Appeal,                                                         have survived as by then he had already
perhaps persuaded by the fact that the          The Court held that parliament had not             suffered irreversible brain damage. The
defendant would yet have to go on to            intended that compensation by periodical           claim failed on causation.
convince a jury in the Crown Court, held        payments would be lower than would be
that the defendant could not be prevented       awarded under the principle that a victim          The claimant appealed, arguing that the
"from adducing evidence as to the               of tort was entitled to be compensated as          judge had failed to understand the
likelihood of the incidence of the relevant     nearly as possible in full for all pecuniary       evidence of the experts and should have
risk eventuating in support of its case         loss and to suggest that s2(9) would only          preferred the evidence of Prof Marks. He
that it had taken all reasonable means to       be triggered in exceptional circumstances          also sought to adduce evidence which
eliminate it".                                  would deprive the new legislative                  was not before the judge in relation to
                                                scheme of its desired beneficial effect.           the views of Prof Hull and his affiliation to
In R v Nelson Group Services                    The legislation was not ambiguous or               the MDU, which was said to create a
(Maintenance) Ltd [1999], the Court of          obscure and therefore reference to                 conflict of interest that should have been
Appeal held that where there had been a         statements made in parliament about the            disclosed to the court. The judge had
failure to follow correct procedures or a       meaning or effect of a particular clause           assessed the level of damages to which
carelessness on the part of the employee,       was not permissible. The setting of the            the claimant would have been entitled, had
the employer was not precluded from             appropriate discount rate in the context           his claim been successful, as £30,000,
establishing that it had done everything        of a lump sum payment was entirely                 being £15,000 for general damages and
reasonably practicable. Regulation 21 of        different in character from an award of            £15,000 for loss of earnings. This was
the MHWR, which provides that, 'Nothing         periodic payments and the problems                 the subject of a cross appeal.
in the relevant statutory provision shall       encountered by calculating lump sum
operate so as to afford an employer a           payments should not infect periodical              The Court held that there was no reason
defence in any criminal proceedings for a       payments.                                          to conclude that the judge had erred in
contravention of those provisions by                                                               fact; the judge's summary of the medical
reason of any act or default', was              The Court should not take into account             issues and judgment on causation was
intended to reverse the effect of that          policy arguments based on issues of                found to be "unimpeachable". The new
case. However, the Court of Appeal in           affordability. This was a matter for parliament.   evidence, which in the opinion of the

Court could have been obtained before         admission, struck out the defence and          Court of Appeal - Brooke, Laws and
trial, would not have discredited Prof Hull   entered judgment for the claimant. On          Smith LJJ
and caused the judge to rely on the           appeal, the judge held that he had             31 July 2006
evidence of Prof Marks. The conflict of       discretion under CPR Part 14.1(5) to hold
interest between Prof Hull's membership       the defendant to its earlier admission or      An opportunity arose for the first time
of the Cases Committee of the MDU and         to permit it to resile from it and concluded   since Callery v Gray (no 1) [2001] and
his position as expert in the case was        that, in the circumstances, the defendant      Callery v Gray (No 2) [2001] for the
submitted by the claimant to be sufficient    should be bound by its admission. The          Court to deal with issues relating to the
to require disclosure, and the failure to     defendant appealed on the ground that it       reasonableness of an ATE premium in
do so sufficient to require the Court to      was entitled as of right to withdraw a         this small personal injury claim. The
set aside the judge's order. The Court did    pre-action admission, that the claimant        Court gave its approval to staged ATE
not agree. The key question was whether       could not show any abuse of process or         premiums and clarified issues relating to
that evidence was independent of the          bad faith and the withdrawal of the            the reasonableness of ATE premiums
parties and the pressures of litigation.      admission would not be likely to obstruct      generally.
Membership of the Cases Committee             the just disposal of the proceedings
would not automatically disqualify a          because the claimant would not suffer          The claimant was injured in a
person from acting as an expert but the       prejudice, only disappointment.                playground. Liability was in dispute but
conflict should have been disclosed to                                                       the defendant was subsequently found
the court and the other party. The Court      Before the appeal was heard, the Court         liable. Damages were agreed at £3,105
suggested that the Civil Procedure Rules      of Appeal handed down its judgment in          plus interest and costs were assessed by
Committee should consider whether the         Sowerby v Charlton [2005], holding that        the district judge at £16,821 including an
requirement for an expert's declaration at    CPR Part 14 had no application to              ATE premium of £5,103. There was
the end of his report should be extended      pre-action admissions of liability, and it     some dispute as to a success fee of
so that any conflict of interest which        was agreed that in the light of that case      100% but this was upheld.
might bring into question the expert's        the judge's decision could not be upheld.
suitability should be disclosed.              The claimant sought to argue that the          The defendant appealed and successfully
                                              judge's decision could be upheld on the        reduced the costs to £12,628. In particular,
George Pullman QC and Clive Rawlings          grounds that the court had inherent            the ATE premium allowed was
for the claimant                              jurisdiction to hear an application to         substantially reduced. The ATE product
Mary O'Rourke for the defendant               strike out a defence where there had           had a three-stage premium with the last
                                              been a withdrawal of an earlier                instalment of £3,510 payable 60 days
                                              admission and that the admission of            before trial. The defendant had included
Pre-action admissions - striking out;         liability gave rise to a binding agreement.    in its bundle a 2002 issue of Litigation
abuse of process
                                                                                             Funding but did not formally put it in
                                              The Court did not accept either of the         evidence. The deputy circuit judge was
Stoke on Trent City Council v Walley          claimant's arguments. The defendant did        considerably influenced by that
[2006] EWCA Civ 1137                          not need the permission of the court to        document and concluded that ATE
Court of Appeal - Brooke, Smith and Wall      withdraw its pre-action admission; such        insurance was available at a cost of
LJJ                                           an admission was evidential only in any        between £450 and £1,350 and that no
31 July 2006                                  subsequent proceedings. A claimant             one would reasonably agree to an ATE
                                              could apply to strike out the defence, or      with such a substantial payment at the
In this case, the council's loss adjusters    part of it, where a pre-action admission       last stage when ATE insurance was
had erroneously admitted liability in a       was withdrawn but the claimant had to          available at less cost for the whole period
claim by its employee in respect of a         show that the defendant had acted in           of the litigation. He reduced the premium
knee injury allegedly sustained when he       bad faith if it was asking the court to find   to £900.
tripped on plastic refuge bags stored in      that the withdrawal of the admission
the foot well of the front passenger seat     would be an abuse of process. This             The claimant appealed on the grounds
whilst he was alighting from a refuse         could not be shown here. There was no          that the judge was wrong to reduce the
truck. The loss adjuster's employee           evidence that the claimant would be            premium in the way he did and wrong
dealing with the claim was later found to     prejudiced in terms of the fairness of the     not to have ordered a detailed
be incompetent and, following a review        trial being affected by loss of evidence or    assessment. The sum of £900 was
of the case on the employee's departure,      the death of witnesses. Of course the          unreasonable taking into account the
the loss adjuster instructed the              claimant would be disappointed but that        risks being insured.
defendant's solicitors to withdraw the        could not be said to obstruct the just
admission. Proceedings were issued. A         disposal of the case. The appeal was
denial of liability followed, the defence                                                    Submissions were invited from various
alleging that the claimant had injured                                                       insurers in the market and the Law
himself by jumping down from the truck                                                       Society. Master Hurst, at the direction of
                                              Brooke LJ commented that there were            Brooke LJ, held a case management
instead of climbing down and that the         strong reasons for giving greater effect to
refuse bags were in fact stored in the                                                       conference following which he provided
                                              a pre-action admission of liability in order   the Court with a report which assisted on
back, behind the front passenger seat.        to avoid uncertainty.
Contributory negligence was also                                                             issues of fact relating to the appeal.
pleaded. The claimant applied to strike       Andrew Hogarth QC and Anthony
out the defence on the ground that it was                                                    The issues were:
                                              Johnson for the claimant
an abuse of process or otherwise likely                                                      (i)      What is the proper approach to
                                              Neil Block QC and David Eccles for the
to obstruct the disposal of the                                                              proportionality in a small personal injury
proceedings, relying on CPR Part 3.4(2).                                                     claim where the ATE premium may
The defendant sought permission to                                                           appear large in comparison with the
                                              Costs - proportionality; ATE premium
resile from its earlier admission.                                                           amount of damages reasonably claimed?
                                                                                             (ii)     What is the proper approach to
The district judge held that the defendant    Rogers v Merthyr Tydfil County Borough         evidence of reasonableness of the
ought to be bound by its pre-action           Council [2006] EWCA Civ 1134                   choice and of the amount of the ATE

premium in such cases?                                                                         irrelevant for him to have decided that the
(iii)    Are both staged/stepped               Andrew Bartlett QC and Nicholas Bacon           claimant had failed to meet the burden of
premiums and single premiums for ATE           for the claimant                                proof. The judge was also entitled to
insurance legitimate for the purposes of       Benjamin Williams for the defendant             conclude on the evidence that the
recovery by a successful claimant, and is      Nigel Cooksley QC and Richard Drabble           claimant could be assisted in his recovery
it reasonable that such premiums should        QC for the interveners                          and that the symptoms would ameliorate.
be wholly or partially block-rated?
                                                                                               David Foskett QC and Robert Percival for
Proportionality: the Court emphasised the      Burden of proof - damages; credibility          the claimant
conceptual distinction between                                                                 Jonathan Watt-Pringle for the first
proportionality and reasonableness. If the     Newman v Laver and another [2006]               defendant
staged premium was necessarily incurred        EWCA Civ 1135
then the compelling conclusion was that it     Court of Appeal - Ward, Rix and Gage LJJ
was a proportionate expense.                   31 July 2006                                    Limitation - PTSD; negligent diagnosis

Legitimacy: the Court could see no             The claimant was injured when his car           McHugh v Deidre Gray (as personal
difference between a two-staged success        was struck from behind by the first             representative of the estate of Charles
fee, the merits of which it endorsed, and a    defendant's car and he hit his head quite       Gray) [2006] EWHC 1968 (QB)
staged ATE premium.                            hard on the headrest. He was in good            QBD - Beatson J
                                               health at the time and aged 55. He              27 July 2006
Size of premium: the fact that an ATE pre-     suffered a whiplash injury and had post
mium is large in comparison with the dam-      concussional symptoms such as                   The claimant issued proceedings against
ages recovered does not mean that it is        dizziness, blurred vision and headaches.        a psychiatrist who had been appointed to
disproportionate. The insurer's assess-        He was unable to work. He also claimed          examine the claimant and report on any
ment of risk in this case was not unrea-       that he had developed bilateral monocular       psychiatric injuries following his involvement
sonable, given the defendant's determina-      diplopia - a rare from of double vision - as    in the disaster at Hillsborough football
tion to go to trial. On the                    a result of the accident. He claimed            ground when many people were killed or
evidence now available, the Court              damages for loss of earnings and care for       injured. The defendant reported that the
considered the judge's reliance on             the rest of his life. The judge held that the   claimant had a moderate degree of PTSD
Litigation Funding was not well founded.       claimant had failed to prove that he was        and that his symptoms should resolve
The total premium payable under a staged       suffering from the condition and concluded      within a matter of months. The claimant
premium model could not be compared            that the symptoms had lasted for some 11        then settled his claim against South
with a single premium model.                   months but had become overlaid with             Yorkshire Police for £2,750. The claimant
                                               psychological factors and the symptoms          alleged that his symptoms did not resolve
Approach of claimant's solicitor: the Court    would ameliorate over the next two or           but rather led to the breakdown of his
was satisfied that the claimant's solicitor    three years.                                    relationship with his girlfriend, depression
had acted reasonably in tying himself to                                                       and drug-taking. He claimed damages for
DAS and that he was not                        The claimant appealed. He argued that           the negligent diagnosis and prognosis.
acting in breach of s4(1) of the Solicitors'   the judge had erred in failing to find that     There was an issue as to limitation and this
Introduction and Referral Code 1990.           he suffered from bilateral monocular            was taken as a preliminary point. The judge
                                               diplopia and had wrongly disposed of the        held that the claimant had constructive
Future procedure: where a claimant has         issue on a mere burden of proof. He also        knowledge of his claim by 1992 and so
entered into a staged ATE insurance            submitted that the judge was wrong to           the primary limitation period expired in
policy, notice should be given to the          reject the claim on the basis that the          1995. There was a 'significant' seven-year
defendant of the trigger points in addition    claimant was putting forward a dishonest        delay in issuing proceedings for which the
to the obligations of CPR Part 44.15(1).       claim when the defendant had not                claimant was responsible. The claimant
                                               asserted that in his defence or at trial and    appealed the judge's refusal to exercise
Evidence: if the size of a second or third     that there was no evidence to suggest that      his discretion to disapply the limitation
stage premium is challenged, the               the symptoms would ameliorate.                  period.
claimant's solicitor can assist the district
judges in assessing the reasonableness of      Dismissing the appeal, the Court of             The judge held on appeal that the first
the premium by setting out in a brief note     Appeal held that the critical difficulty with   instance judge was entitled not to exercise
the reason why they chose the particular       the claimant's case was that there was no       his discretion. He had taken into account
ATE product and the basis on which the         evidence that the condition had organic         the period of delay and was entitled to find
premium is rated.                              origins. The majority of the experts said       that, for the purposes of s33(3)(a) of the
                                               that there was no indication of organic         Limitation Act 1980 it was significant. With
                                               origin for the disease and the only             reference to s33(3)(b), the judge was entitled
Self-insurance of the premium: the Court
                                               diagnostic tool was the consistency of the      to find that, as regards any reduction in the
confirmed that it is permissible for the
                                               claimant's account of his symptoms.             cogency of the claim, any prejudice was not
premium itself to be insured by the policy
                                               Therefore, all depended upon his credibility.   more than minor, and he had properly taken
in the event of failure or partial success
                                               There had been some inconsistencies in          into account that, while the claimant stood
(Callery v Gray (No 2) [2001]).
                                               his evidence and a tendency to exaggerate.      to lose a potentially valuable claim, the
                                               The judge was entitled to dispose of the        defendant was faced with a stale claim and
The appeal was allowed and recovery of         issue on the burden of proof. There had         prejudice would be caused to those who
the ATE premium was allowed as claimed.        been no general case that the claimant          had financial responsibility for it. The judge
In an approved note to the unanimous           had fabricated his symptoms and the             had properly weighed up the strength of
judgment, Smith LJ urged solicitors and        judge had not silently accepted such a          the claim and its value in coming to his
ATE insurers to be more rigorous in their      case but he had weighed up all the              decision. The appeal was dismissed.
assessment of the prospects of success at      submissions relating to the claimant's
the third stage and to put a stop to weak      credibility. He had not concluded that the
claims even at such a late stage.                                                              G Mansfield QC for the claimant
                                               claimant was fabricating his symptoms; if       R Seabrook QC for the defendant
                                               he had done so it would have been

                                                 The 78-year-old claimant was getting off a
Meningococcal septicaemia                        bus when she tripped on a hole in a pave-
                                                 ment maintained by the defendant and
W v Abraham [2006]                               fell, injuring her right knee and ankle.
Out of court settlement                          Liability was in dispute. The knee was
27 January 2006                                  painful and swollen and required dressing
                                                 twice a week for three weeks. A steroid
The claimant was aged 17 when she                injection provided some temporary
presented to her GP with flu-like symptoms,      improvement. She limped and needed a
tingling in her arms and legs and a rash         walking stick. She had since become
over her stomach and legs. The GP                largely housebound and the accident
diagnosed a viral illness and advised the        accelerated pre-existing osteoarthritis in
claimant to take paracetamol and drink           her knee by six months.
plenty of fluid.
Her condition worsened and she was               Award: £3,250
admitted to hospital where a diagnosis of
meningococcal septicaemia was made.              Jane Clifton for the claimant
She remained in intensive care for six           Mr Burns for the defendant
days. She alleged that the GP was
negligent in failing to diagnose meningitis
and refer her for urgent treatment. Liability    Knee, rib and spleen
was admitted.
                                                 Boyd v Hovey [2006]
The claimant had a left trans-tibial             Canterbury County Court - HHJ Cameron
below-knee amputation, amputation of the         31 March 2006
right ring finger and amputation of the left
index, ring and little fingers. She was fitted   The claimant, aged 37, was thrown from
with a leg prosthesis, could only walk           his motor cycle when the defendant's car
short distances and could not run at all.        emerged from a side road and collided
She suffered from pain at the base of the        with him. Liability was admitted. The
stump and phantom limb pain. She had a           claimant sustained a fracture of the tibial
loss of dexterity and discomfort in her          plateau of his left knee, a ruptured spleen
hands and fingers. She had numerous              and fractured left ribs. He was in hospital
scars.                                           for two weeks and discharged in a
She was self-conscious of her appearance          wheelchair. He could not weight bear for
and suffered from panic attacks and              three months and was highly dependent
depression. She was likely to be able to         on others as a consequence. He wore a
work only part-time and her chosen career        knee brace for six months and could
as an actress was likely to be severely          weight bear after that time. He suffered
affected.                                        with aching and discomfort in the knee
                                                 and slight restriction of movement. He
Out of court settlement: £1,500,000              could not walk long distances and had
including £105,000 for PSLA and a Smith          trouble descending stairs. He could not
v Manchester award.                              continue working as a pipe fitter and
                                                 retrained as a mechanic, a job which was
                                                 less well paid. Symptoms were expected
Index finger                                     to gradually deteriorate over the next ten
                                                 years leading to the onset of post-traumatic
Ball v Belfield [2006]                           osteoarthritis.
Preston County Court - DJ Ashton
July 2006                                        Award: £231,079.13 including £25,000 for
The claimant suffered the loss of the tip of
his index finger which was bitten off by the     Graham Aldous for the claimant
defendant's flat coat retriever as the           Vizards Wyeth for the defendant
claimant posted a leaflet through the door.
The district judge was satisfied that more
could have been done to prevent injury.          Interesting reading

The claimant lost about one inch from the        John Leighton Williams of Farrar's
top of his finger which made using a knife       Buildings discusses the shortcomings of        Please contact Jason Rowley at the address below if
and fork and carrying out basic DIY a            the Compensation Bill Part 1 in 'What          you wish to discuss these or any other legal
problem.                                         compensation?' page 934 of the Solicitors      matters.
                                                                                                    Jason Rowley             City office
                                                 Journal Vol. 150 No. 28.                           Managing Partner         Asia House
Award: £7,000                                                                                       Vizards Wyeth            31-33 Lime Street
                                                                                                    Riverbridge House        London EC3M 7HT
                                                 The enforceability of costs under                  Anchor Boulevard
                                                 retrospective CFAs is examined by Roger            Crossways
Knee and ankle                                                                                      Dartford
                                                 Mallalieu of Hailsham Chambers in the              Kent DA2 6SL
                                                 Personal Injury Law Journal July/August
Priest v Liverpool City Council [2006]           2006 pages 9-11.                                   Tel:   020 7400 9999
                                                                                                    Fax: 020 7400 9990
Liverpool County Court - HHJ Morgan                                                                 email:
11 July 2006

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