Catalano v Espley-Tyas Development Group Ltd

Costs – Order for costs. For the purposes of the Qualified One-way Costs Shifting (QOCS) regime in the funding of cases, the concept of a pre-1 April 2013 funding arrangement did not just include an agreement where services had in fact been provided before 1 April 2013 but also an agreement made before 1 April 2013, for the provision of such services in the future. Accordingly, the Court of Appeal, Civil Division, dismissed the claimant's appeal against the judge's decision that the QOCS regime was not applicable.

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