“…as a matter of ordinary interpretation, bearing in mind the purpose of certification, it is implicit that the solicitor who signs the certificates must be readily identifiable on the face of those certificates. It is inherent in the concept of certifying or attesting to a matter before a court of law, at least in circumstances where the CPR requires (as it does here) that a matter is certified or attested by an individual, that the signatory should disclose their identity to the court.”
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Master Nagalingam directs a claimant to redraw his bill of costs of almost £1m in phases to comply with the requirements of CPR 47 PD 5.8(8). The claimant had argued that due to considerable developments in the case, the case managing court had accepted that updated costs budgets were necessary and these had duly been prepared and served. However, the revised budgets did not reach the stage of a costs management hearing and were never approved. Notwithstanding, the claimant argued, as the revised budgets were ordered by the Court the initial approved budget was deemed to be superseded, there was therefore no approved budget in place and CPR 47 PD 5.8(8) did not apply. Thus a phased bill of costs was not required. The Master disagreed.