When deciding to order costs against a non-party, it was not enough to identify the non-party closely with a party, but must follow all the guidelines set out in Symphony. The White Book note 62/2/7 is inadequate in its description of the rules.
Citations:
Times 14-Jan-1999, Gazette 27-Jan-1999
Jurisdiction:
England and Wales
Citing:
Applied – Symphony Group Plc v Hodgson CA 4-May-1993
Nine rules were set out for allowing a costs order against someone who is not a party to the action. Such orders should be exceptional. The normal rule is that witnesses in either civil or criminal proceedings enjoy immunity from any form of civil . .
Lists of cited by and citing cases may be incomplete.
Costs
Updated: 10 April 2022; Ref: scu.90487