PART 36

Not more , you groan . Well yes. Poor Sales J. after staggering through a 95 day trial in F & C LTD V BARTHELEMY stumbled at the final post in his 303 page judgment. He sought to grant Part 36 rewards where an offer had been made but it was conspicuously not a Part 36 [proposal. One cannot import Part 36 rewards into the general costs regime. Judgment is (2012) EWCA Civ. 843 published on june 22nd.