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
 EWHC 9025 (Costs),  EWCA Civ 250,  CP Rep 34,  3 Costs LR 341
England and Wales
Application for leave – Wulfsohn, 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