An offer to settle must be backed by a payment into court in debt actions. The defendant here could have protected his position by a payment into court, and therefore a Calderbank offer was ineffective.
Ind Summary 27-Jun-1994,  PIQR Q110
Rules of the Supreme Court 22.14
England and Wales
Cited – Butcher v Wolfe and Another CA 30-Oct-1998
The parties had been partners in a family farm. On dissolution there was a dispute as to apportionment of costs. An offer had been ‘without prejudice save as to costs’.
Held: Costs may be denied to a plaintiff who had received a Calderbank . .
These lists may be incomplete.
Updated: 16 May 2021; Ref: scu.89274