Wulfsohn, Regina (on the Application of) v Legal Service Commission: CA 8 Feb 2002

The claimant appealed against a costs award made to him when acting as a litigant in person.
Held: The appeal was allowed. A litigant in person may be able to claim for the costs of his research, subject to the cap in the rules.
Schiemann LJ said: ‘If one reads together 48.6(2) and (4) one sees that, in principle, a litigant in person is entitled to compensation for his time, and the rate is fixed by Statutory Instrument and at all relevant times was andpound;9.25 per hour. But there is a cap which is that however long a litigant spends in person doing things he cannot recover more than, broadly speaking, two-thirds of what his legal representatives would have done if he had had a lawyer.’


Schiemann LJ, Rix LJ


[2002] EWHC 9025 (Costs), [2002] EWCA Civ 250, [2002] CP Rep 34, [2002] 3 Costs LR 341


Bailii, Bailii


Civil Procedure Rules 48.6


England and Wales


Application for leaveWulfsohn, Regina (on the Application of) v Legal Services Commission CA 31-Aug-2001
Mr Wulfsohn sought (and was granted) leave to appeal against an assessment of the costs payable to him as a successful litigant in person. . .
Lists of cited by and citing cases may be incomplete.

Costs, Civil Procedure Rules

Updated: 23 June 2022; Ref: scu.216873