Interest exclusive Part 36 Offers in proceedings

HORNE v PRESCOT (NO.1) LTD [2019] EWHC 1322 (QB)

Disagreeing with Judge Robert Owen QC in Potter v Sally Montague (Nottingham CC), HHJ Nicol found that a Part 36 Offer made in detailed assessment proceedings and expressed to be exclusive of interest was a valid Part 36 Offer.

“Interest would be payable on the costs and the costs of the detailed assessment proceedings, but that would be added automatically by virtue of the Judgments Act: it did not need to be claimed.”

HORNE v PRESCOT (NO.1) LTD [2019] EWHC 1322 (QB)