Interest exclusive Offers in detailed assessment 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 Offer made in detailed assessment proceedings and expressed to be exclusive of interest was a valid 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.”

*this decision has effectively been overturned by the Court of Appeal in the case of King v City of London Corporation [2019] EWCA Civ 2266*

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