PI Brief Update, December 2018 Welcome to the latest issue of PI Brief Update, a free newsletter, providing you with industry news and case summaries each month. It is written by our team of PI barristers and currently goes out to around 10,000 people, most of whom are lawyers or claims handlers in the personal injury field. You have received this newsletter at newsletter@newslettercollector.com, because you are signed-up to our newsletters via lawbriefpublishjing.com, www.lawbriefupdate.com or www.pibriefupdate.com. Scroll to the end for contact, unsubscribe info etc. If you'd like to advertise or write articles for us then please email us at mail@lawbriefpublishing.com. Anthony Johnson & Tim Kevan (editors) Summary of Recent Cases - Substantive Law Kelly Wallett v Michael Vickers [2018] EWHC 3088 (QB): Wallett v Vickers represents the latest development in the growing seam of caselaw on the illegality defence in the context of road traffic accidents. The Claimant's partner had died in a car crash whilst driving at speed. At first instance, Mr Recorder Kirtley concluded that the Claimant's claim for damages was barred by the principle of ex turpi causa. The Claimant appealed. In giving judgment, Males J considered the case of Gray v Thames Trains Ltd [2009] UKHL 33. It was noted that in Gray, the offence in question had been manslaughter, which was a very serious offence and in that case the question of whether all criminal offences would constitute turpitude had not arisen. Males J stated at §37-38 that: "Similarly in Gray and Henderson, despite the apparently unqualified statements of principle ("you cannot recover for damage which is the consequence of your own criminal act"), the question whether all criminal offences would constitute turpitude did not arise. Both were concerned with manslaughter by diminished responsibility, which on any view is a very serious offence. It requires proof of an intention to kill, albeit an intention which is affected by an abnormality of mental functioning. On any view, therefore, such offences would amount to turpitude for the purpose of the ex turpi causa defence. Towards the other end of the spectrum, careless driving is a criminal offence but nobody would suggest that careless driving by the claimant prevents the recovery of damages (reduced as appropriate on account of contributory negligence) in a road traffic case where both drivers are partly to blame. In such a case the recovery of damages does not offend public notions of the fair distribution of resources and poses no threat to the integrity of the law. On the contrary, the recovery of damages is in accordance with public policy. The claimant is not compensated for the consequence of his own criminal act. Rather, as a result of the reduction for contributory fault, he is compensated only for that part of the damage which the law regards as having been caused by the defendant's negligence." Males J went on to consider the case of McCracken v Smith [2015] EWCA Civ 380. He stated at §43: "In my judgment McCracken is a binding authority that in the absence of a criminal joint enterprise between the claimant and the defendant, dangerous driving by the claimant will not bar a claim pursuant to the ex turpi causa principle. Rather, such a claim is to be determined in accordance with principles of causation (has the conduct of the defendant made a material contribution to the claimant's injuries?) and contributory negligence (should the damages be reduced by reason of the claimant's own fault?). These principles are sufficient to give effect to the requirements of justice and public policy." Males J concluded that the Recorder had been wrong to conclude that a driver who died in a car crash while driving down a dual carriageway at speed had been engaged in a criminal joint enterprise of dangerous driving with a driver of another car which barred a damages claim by the deceased's partner on the grounds of ex turpi causa. Although dangerous driving was a more serious offence than careless driving, it was held that in the absence of a criminal joint enterprise between the Claimant and the Defendant, dangerous driving by a claimant would not bar a claim pursuant to the principle of ex turpi causa. Instead, the claim should be determined using the normal principles of causation and contributory negligence. Half Price for Barristers, Experts, Academics, etc If you are a barrister (in independent practise), a single user expert, an academic, an independent consultant, or other self-employed single user then did you know that you can get an annual subscription to PIBULJ.COM for half of the standard rate? That means for you the cost is just £149+vat per year for full membership of the UK's leading online personal injury journal, giving you access to the latest news and important case opinions from leading personal injury barristers and solicitors, monthly CPD tests, video masterclasses, online book chapters, and a huge archive of content stretching back over 9 years. So what are you waiting for? Click below for more information or to sign-up now. Summary of Recent Cases - Costs Andrew Graeme Waring v Mark McDonnell (unrep., Brighton County Court, 6 November 2011): The Claimant and Defendant had been cycling in opposite directions and collided head-on. Both sustained personal injury and brought claims for damages. The Judge found for the Claimant and dismissed the Defendant's counterclaim. It was held that the Defendant was not entitled to the protection of qualified one-way costs shifting in relation to the costs of the Claimant's successful claim. This was because he was not an unsuccessful claimant in the Claimant's claim, but an unsuccessful defendant. The court expressly disagreed with the approach taken in Ketchion v McEwan (unrep., Newcastle & Tyne County Court, 28 June 2018) where it had been held that, in CPR 44.13, the word "proceedings" included both a claim and counterclaim. HHJ Venn stated that, if the approach in Ketchion was followed, a number of undesirable consequences would arise, including the fact that insurers of defendants would be incentivised to bring counterclaims for damages for personal injury to ensure there would be no liability for costs. Astex Therapeutics Ltd v Astrazeneca AB [2018] EWCA Civ 2444: In this case the Respondent had made an offer which was significantly more favourable to the Appellant than the outcome that the Appellant achieved at trial. However, the offer was not made under CPR Part 36 and therefore there were no automatic costs consequences (following F&C Alternative Investments (Holdings) Ltd v Barthelemy [2012] EWCA Civ 843). However, the offer was relevant under CPR Part 44 which obliges the court to consider all the circumstances of a case when deciding the order for costs. The court considered that although there might be some cases where the refusal to accept a reasonable offer was capable of justifying an award of indemnity costs, that situation would only arise where the failure to accept such an offer was itself unreasonable. In this case it was held that the Appellant's conduct did not justify an order for indemnity costs and that part of the order was set aside. Summary of Recent Cases - Civil Procedure & Evidence (1) WH Holding Ltd, (2) West Ham United Football Club Ltd v E20 Stadium LLP [2018] EWCA Civ 2652: The Appellants (collectively, "West Ham") had applied for disclosure of six emails in respect of which a claim of privilege had been made by the Respondent ("E20"); it also applied under CPR 31.19(6)(a) for the court to inspect the emails, for the purpose of deciding the main application. As a reminder, insofar as relevant CPR 31.19 provides: "... (3) A person who wishes to claim that he has a right or a duty to withhold inspection of a document, or part of a document, must state in writing - (a) that he has such a right or duty; and (b) the grounds on which he claims that right or duty. ... (5) A party may apply to the court to decide whether a claim made under paragraph (3) should be upheld. (6) For the purpose of deciding an application under paragraph (1) (application to withhold disclosure) or paragraph (3) (claim to withhold inspection) the court may - (a) require the person seeking to withhold disclosure or inspection of a document to produce that document to the court; and (b) invite any person, whether or not a party, to make representations ..." The underlying litigation concerned a contractual dispute between West Ham and E20. The six emails at the heart of this application were sent between E20's board members, and between the board members and stakeholders, and were said to consist of discussions about "a commercial proposal for settling the litigation". Litigation privilege was asserted on the basis that the emails were created with the dominant purpose of formulating an offer of settlement, and that assertion was upheld by the judge relying on Director of the Serious Fraud Office v Eurasian Natural Resources Corp Ltd [2018] EWCA Civ 2006 (and, at the same time, refusing to inspect the documents under COR 31.19(6)(a), relying on the dicta of Beatson J in West London Pipeline and Storage Ltd v Total UK [2008] 2 CLC 258 to the effect that the statement of truth on the disclosure list was to be taken as conclusive unless one of a number of exceptions was satisfied). The Court of Appeal (Sir Terence Etherton MR, Lewison LJ, Asplin LJ) overturned that decision. It was trite that litigation privilege was engaged when adversarial litigation was in reasonable contemplation, and once engaged, it covered communications between the parties, their solicitors and third parties seeking advice or information for the sole or dominant purpose of conducting the litigation. Further, it was also well-established that the concept of 'conducting litigation' included deciding whether to settle it: Director of the Serious Fraud Office v Eurasian Natural Resources Corp Ltd. However, Director of the Serious Fraud Office v Eurasian Natural Resources Corp Ltd did not go so far as to extend litigation privilege to purely commercial internal discussions as to the most commercially viable options for settlement. That, naturally, was subject to the orthodox principle that litigation privilege would protect documents in which advice or information obtained for the sole or dominant purpose of deciding whether to settle was mixed with non-privileged material, and could not be disentangled, as well as those non-privileged communications which would otherwise reveal the nature of the advice or information. It was therefore not necessary to consider whether the court should inspect the documents under CPR 36.19(6)(a). But obiter, the Court of Appeal considered that Beatson J's formulation of the relevant principles in West London Pipeline and Storage Ltd v Total UK was overly narrow and restrictive. The proper approach was that the power to inspect a document is a matter of general discretion, to be exercised in accordance with the overriding objective. Relevant factors would include (a) the nature of the privilege claimed (b) the number of documents involved and (c) their potential relevance to the issues; and when inspecting documents the court should always be astute to the danger of looking at them out of context. Stephen Mark v (1) Universal Coatings & Services Ltd, (2) Barrier Ltd [2018] EWHC 3206 (QB): This case concerns the obligation in CPR PD 16 paragraph 4.3 to serve a medical report and schedule of loss with the particulars of claim in a personal injury action. The Claimant allegedly suffered silicosis and massive pulmonary fibrosis as a result of inhaling silica dust during his employment with the Defendants. He instructed solicitors in 2013, and in 2015, shortly before expiry of the limitation period, a claim form was issued and an order obtained extending the time for extending time for service of the claim form, particulars of claim and supporting medical evidence. Thereafter, the solicitors went into administration and new ones were appointed, who served the claim form and particulars within the (extended) time limit, but no accompanying medical evidence. The medical report and a draft schedule of loss eventually followed several weeks later. The Defendants successfully sought strike-out of the Claimant's claim. The judge found that the obligation in CPR PD 16 paragraph 4.3 was that the claimant "must" serve the medical report and schedule of loss with the particulars of claim, and that paragraph therefore contained an implied sanction such that the principles of relief from sanctions were engaged. He refused relief and struck out the claim. The High Court (Martin Spencer J) reversed that decision. No sanction (implicit or otherwise) was engaged, and so the judge was wrong to find that the Denton principles applied. First, although CPR PD 16 paragraph 4.3 used the word "must", that was not determinative. The word "must" was used liberally in the CPR, and if relief from sanctions needed to be applied for in all cases where a rule or practice direction used it, absurd results would ensue and the courts would be inundated with wholly unnecessary applications. Second, CPR PD 16 paragraph 4.3 was not in the category of rules using the word "must" where an implied sanction ought to be applied. CPR PD 16 paragraph 4 applied to all cases, from the most simple to the most complex. It was plain that in complicated cases there was a limit to what could be achieved at the early stage of service of the particulars of claim, and that sometimes it would be better to refrain from serving accompanying medical evidence, than to serve a document which was unhelpful and uninformative. Accordingly, the judge had erred in his approach and the claim was reinstated. Following Stephen Mark v (1) Universal Coatings & Services Ltd, (2) Barrier Ltd, in appropriate cases, the proper approach will not to be to apply the relief from sanctions principles, but to consider whether a proportionate sanction ought to be applied for the non-compliance - such as unless orders, penalisation in costs, etc. PI Practitioner - each issue a particular topic is highlighted, citing some of the useful cases and other materials in that area. This month's issue focuses on applications for permission to bring in additional fields of medical evidence, and specifically the case of Sharron Denise Hall v Derby Teaching Hospitals NHS Foundation Trust [2018] EWHC 3276 (QB), which provides a stark illustration of 'how not to do it'. It is suggested that the following practical points of importance emerge from the judgment: (1) Exercise caution before presumptively instructing the relevant expert, before the application has been heard. Implicit in the judgment is a recognition of the fact that just because an expert report has been obtained, a grant of permission is not necessarily more likely to be obtained. Further, if the expert is presumptively instructed and permission is then refused, it will not only be very costly, but it may also be hard to unwind the consequences of the instruction (for example in this case, the other experts had all been asked to comment on the evidence of the new expert in their reports). (2) Claimant practitioners should be mindful of the fact that, if the further evidence is sought because it is hoped that it will contain a specific conclusion that will bolster the claimant's case, there is an inherent risk that the conclusion may not be forthcoming. If so, the evidence is unlikely to add anything and is therefore bound to be refused, in which case the whole exercise will have been little more than an expensive fishing expedition. (3) Where possible, parties should endeavour to agree a common approach, short of seeking formal Part 35 permission, to accommodate the potential need for further expert opinion on specific points. If that can be achieved, many of the risks and costs identified above could be avoided. (4) Where the evidential and procedural picture has moved on since an application has been made, that should be clearly pointed out to the judge in a concise statement or case summary (especially since the judge is likely to read the N244 as originally framed as her first port of call), and the potential difficulties for the applicant arising therefrom should be dealt with head-on. In Sharron Denise Hall v Derby Teaching Hospitals NHS Foundation Trust, the Claimant had undergone a laparoscopic cholecystectomy, during which her bile duct was negligently damaged. In consequence, she had to undergo invasive open surgery which, though successful, left her with a variety of ongoing symptoms including chronic abdominal pain. The Claimant obtained permission at an initial CMC to appoint experts in psychiatry, pain management and general surgery; at a further CMC she obtained permission to appoint a neurologist on account of a problem which the Claimant was experiencing in her foot, manifesting in weakness and instability. On the neurologist's recommendation, a full spinal MRI scan was taken, revealing two lesions on the Claimant's spine. The neurologist explored a range of explanations for the foot symptoms, including that they were being caused or contributed to by the lesions, though he considered this unlikely. Ultimately, he opined that he could not reach a firm conclusion in the absence of input from a neurosurgeon (the aetiology and treatment of such lesions being more within the remit of neurosurgery than neurology). He strongly recommended that a neurosurgeon be instructed. The Claimant obtained short supplemental reports from her other experts, supporting the instruction of a neurosurgeon. The Claimant proceeded to issue the application for permission to rely on the evidence of a neurosurgeon, arguing that "Without the requested neurosurgical evidence her ability to prove essential elements of causation and quantum would be hindered significantly". Having issued the application, and no doubt in anticipation of the hearing, the Claimant instructed a neurosurgeon to prepare a desktop report, together with a report following a physical examination of the Claimant. In those reports, the neurosurgeon made the following comments about the lesions: namely, that they resulted from constitutional degenerative change and were unrelated to the index accident; that they were asymptomatic at the time of the negligence but would become symptomatic faster than they would have done in the absence of the negligent surgery (because the Claimant's loss of muscle strength and weight gain reduced her ability to stave off the effects of the lesions); and that the Claimant was likely to require future surgery to treat the lesions but her recovery might be affected by the long-term sequelae of the index accident. Of the foot symptoms, he said that "Clinical examination does not explain the basis of this lady's right leg symptoms", and concluded that "the right leg symptoms are related to chronic abdominal pain as suggested by [the pain consultant], compounded by psychiatric issues as suggested by [the psychiatrist]". Thus, the neurosurgeon was unable to find any lesion involvement in the foot symptoms, and deferred to the opinion of existing experts as to the proper diagnosis. Unsurprisingly in these circumstances, the court struggled to identify what the neurosurgeon's evidence could add, from the perspective of the trial judge. The evidence failed to show what the Claimant had set out to show, namely that the lesions and/or the foot symptoms were caused by the index accident; indeed it showed the opposite. As such, "in simple objective terms there is now common ground and so the need for the formal introduction of expert comment by way of Part 35 permission is not needed to prove what is agreed". The court was equally unimpressed with what it regarded as the Claimant's "opportunistic" attempt to recast her application, shortly before the hearing, in light of the neurosurgeon's report. She now argued that the evidence was necessary precisely because it showed that the foot symptoms were unrelated to the lesions, and that neither were directly caused by the index accident, which assisted the parties and the court in narrowing the causation issues. Further, the reports demonstrated the interaction between the long-term sequelae of the negligent surgery and (a) the back pain caused by the lesions, (b) the foot symptoms, and (c) possible future surgery to remove the lesions. The first argument was rejected essentially for the reasons given above, and the second because there was no need for neurosurgical evidence to deal with these issues. As such, the application was rejected. The judge had much to say about the Claimant's presentation of the application, including the preparation of the bundles, the hearing estimate, and her representatives' failure to focus tightly on the medical evidence as it stood at the date of the application. But more fundamentally, the judgment calls into question the sense of the approach no doubt adopted by many (claimant) practitioners when faced with similar circumstances - that is, the approach of making an application under Part 35 on the back of a recommendation for further evidence by an existing medical expert, and instructing the expert in advance of the application hearing so that the court has the 'benefit' of the expert's (sometimes draft) opinion. Practitioners should rethink this approach, and consider carefully the judge's suggested approach of seeking to agree a way forward outside the scope of Part 35. Industry News Crash-for-cash trio sentenced... Top judge calls for ABS transparency amid 'commercialisation' of personal injury... Landmark jail sentence for man who stole client data for CMCs... Motorists with poor vision still driving despite expert advice... Clock change causes increase in road accidents... Civil Liability Bill clears Commons with no exemption for children... Experts raise safety concerns about cardboard baby boxes... Woman awarded £20 million from the NHS for brain injury... Hernia mesh complications 'affect more than 100,000'... Supreme Court refuses appeal bid from firm denied PI costs... PIBU Law Journal Summaries, November 2018 Personal Injury Articles | FREE BOOK CHAPTER from 'A Practical Guide to Relief from Sanctions Post-Mitchell and Denton' by Peter Causton Chapter Two - Background History: From Woolf to Jackson To Dyson. Prior to the implementation of the Jackson reforms, it was considered that the courts had become too tolerant of parties' non-compliance with orders, rules and practice directions and the delays this non-compliance caused... | Editorial: Pre-Action Disclosure of Financial Documents in Credit Hire Cases - Aidan Ellis, Temple Garden Chambers As long ago as 2004, in the course of carving out the impecuniosity exception in Lagden v O'Connor, Lord Nicholls expressed the hope that the parties 'should be able to agree on standard enquiries, or some other means, which in practice can most readily give effect to the test of impecuniosity'. In practice, whilst most Courts now... | Fundamental dishonesty in occupational disease claims (part 2) - Paul Debney, Weightmans LLP In last month's edition, Paul Debney examined the early reported decisions of findings of fundamental dishonesty in disease claims, with specific reference to a claimant who was found to have lied about the provision and wearing of hearing protection and another who was found to have falsely stated that he had made no previous claim for the same disease... | FREE CHAPTER: The History And The Science (from 'A Practical Guide to Claims Arising from Delays in Diagnosing Cancer' by Bella Webb) Chapter Two - The History and the Science. This chapter will look at the trend towards an increase in delayed cancer diagnosis claims and the rationale and statistics that underlie it. It will then go on to look at what we actually mean by cancer in medical terms... | | FREE BOOK CHAPTER from 'A Practical Guide to Vicarious Liability' by Mariel Irvine Chapter One - Overview. There have been at least five decisions of the Supreme Court relevant to vicarious liability since 2012. A topic of importance in a minority of cases, and sometimes described as 'geeky', has been forced into the spotlight... | Vicariously liability for an assault out of work time and off work premises - Simon Anderson, Park Square Barristers Can an employer be held vicariously liable for an assault by a director that takes place on an employee out of work time and off the premises? Yes, according to the Court of Appeal in Bellman v Northampton Recruitment Limited [2018] EWCA Civ 2214... | | Case Summary: M v Morton - Andrea Ribchester-Hodgson & Sarah Wright, Spencers Solicitors The Claimant, M, was driving her vehicle along the road when the Defendant's vehicle pulled out of a lay-by and collided with the passenger side of the Claimant's vehicle, pushing her into the middle of the road... | Motor Insurance / MIB Update - Julie-Anne Luck, 9 St John Street Chambers The potential impact of recent UK and European decisions upon the cost of motor insurance and claims following road traffic accidents cannot be underestimated. The industry is awaiting appeals on two important decisions, which have caused ripples for insurers and the MIB alike... | CPD Information Reading PIBULJ articles can help to meet the CPD requirements for solicitors, barristers and others. For further details see our CPD Information page. | One Month Trial If you haven't subscribed yet there's no need to miss out. You can join for one month for just £1. Access the trial now! |
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| Case Summary: CS v Alan Smith, Northampton CCMCC - Emma Melia & Sarah Wright, Spencers Solicitors The Claimant (age 32 at the time of the accident) was riding a Suzuki GS500 motorbike. He went round a roundabout when he noticed two other cars in front of him. They were indicating to turn right which prevented the Claimant from overtaking them... | Balancing the benefits: yoga's healing power has a valuable place in brain injury rehabilitation - Emma Dryden, George Ide LLP The effects of traumatic or non-traumatic brain injury depend upon a number of factors but, in general, symptoms can range from physical and cognitive to emotional and behavioural... | Summary of Recent Cases, November 2018 Here is a summary of the recent notable court cases over the past month... | PI Practitioner, November 2018 Each issue a particular topic is highlighted, citing some of the useful cases and other materials in that area. This month: Surrey County Council v Hilliard (2018)... | | Clinical Negligence Medicine by Dr Mark Burgin | Helping Doctors Who are Suicidal 2018 - Dr Mark Burgin Dr Mark Burgin BM BCh (oxon) MRCGP considers a different approach to suicide based upon the biopsychosocial model and response to potentially modifiable risk factors... | How Will the New Advice for Paediatric Experts Affect the Availability of Experts for Defence Work in Family Courts? - Dr Mark Burgin Dr Mark Burgin BM BCh (oxon) MRCGP DCH raises concerns that the new guidance for paediatric expert witnesses tightens the availability of experts prepared to consider the emotional evidence that might support parents... | Book Reviews | Book Review - 'Clinical Practice and the Law: A Legal Prima for Clinicians' by Giles Eyre Published by Professional Solutions Publications London (2018). Reviewed by Professor Hugh Koch. | PIBULJ.TV - masterclasses from the experts Episode 6: 'Masterclass on Litigating Employers' Liability Claims After the Enterprise Act' Andrew Roy, 12 King's Bench Walk A one hour practical guide on litigating employers' liability claims after the Enterprise Act. Includes: the likely effects of s69, circumventing or mitigating the effects of s69, conventional common law principles, enhanced common law duties, direct application of European legislation, Francovich actions, other duties, practical considerations. | Episode 5: 'RTA Personal Injury: a 2015 Update - What Is Happening to PI in 2015?' Andrew Mckie, Clerksroom Andrew Mckie from Clerksroom presents a 35 minute guide to the latest developments in RTA personal injury claims. Covers fundamental dishonesty, inducements in PI cases, CUE for claimants, pre-medical offers, MedCo, and further problems. |
Get Your Message Heard by 10,000 Readers | Do you offer a product or service to lawyers? Now you can place your ad in this newsletter and be seen by around 10,000 UK based PI lawyers and other personal industry professionals. Contact us now: mail@lawbriefpublishing.com or 0844 5 873 283 | Expert Witness Corner We have special advertising rates for expert witnesses. To advertise in this section, please email mail@lawbriefpublishing.com for more details or telephone 08445 UPDATE (08445 873 283). Clinical Psychology Prof Hugh Koch Adults & children, all PI, employment & sport, nationwide www.cv.hughkoch.com & www.hughkochassociates.co.uk. Psychiatry Dr Gaius Davies Emeritus Consultant Psychiatrist, King's College, Bethlem Royal and Maudsley Hospitals. Reports for PTSD and other stress related disorders and general psychiatric problems. Email: gaius.davies@btopenworld.com. Tel: 020 8650 8764. The Authors | Harriet Wakeman, Temple Garden Chambers Harriet is developing a broad civil and public law practice, including personal injury, health and safety, credit hire and employment law. Harriet acts in both an advisory and representative capacity. HarrietWakeman@tgchambers.com |
| Juliet Wells, Temple Garden Chambers Juliet is developing a practice in Chambers’ core areas, with an emphasis on personal injury, health and safety, employment law, public law and extradition. She regularly appears in the County Court in applications, CMCs, small claims and fast track trials, and appeals, and is building a busy paper-based practice. JulietWells@tgchambers.com |
| Tim Kevan, www.timkevan.com Tim Kevan is a co-founder of Law Brief Publishing. He practised as a barrister for ten years at 1 Temple Gardens (now Temple Garden Chambers) specialising in PI, credit hire and civil fraud. During that time he wrote or co-wrote ten law books. He has since written two legal comedy novels for Bloomsbury Publishing based on the BabyBarista blog which has featured on both The Times and Guardian online. |
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