Jonathan Alexander Ltd v Proctor: CA 19 Dec 1995

A company represented in proceedings by a director is not a litigant in person, and therefore has no expenses or costs claimable from the other party.
Hirst LJ said: ‘. . the ordinary meaning, as I understand it, of the description ‘litigant in person’, viz an unrepresented individual’.
Peter Gibson LJ said: ‘A litigant in person in ordinary parlance is a party to litigation who represents himself by appearing in court himself. If someone other than himself represents him, then notwithstanding that that other person is his agent, that party is not a litigant in person’.

Judges:

Hirst LJ, Peter Gibson LJ

Citations:

Times 03-Jan-1996, Ind Summary 22-Jan-1996, [1996] 1 WLR 518

Statutes:

Litigants in Person (Costs and Expenses) Act 1975, County Court Rules 1981 Order 38 r17

Jurisdiction:

England and Wales

Cited by:

DistinguishedAndre Agassi v S Robinson (H M Inspector of Taxes) (No 2) CA 2-Dec-2005
The taxpayer had been represented in proceedings throughout by tax law experts, Tenon Media, who were not legally admitted, but had a right to conduct litigation under the 1990 Act. The Inspector objected to paying costs as if the representatives . .
Lists of cited by and citing cases may be incomplete.

Company, Costs

Updated: 09 December 2022; Ref: scu.82579