Civil procedure – Expenses – Certification of skilled witness. Sheriff Court: In a personal injuries action in which the pursuer, who had suffered a whiplash injury, lodged a motion for decree in terms of minutes of tender and acceptance and for certification of a consultant orthopaedic surgeon as a skilled witness, the court refused that part of the motion seeking certification, holding that in the circumstances the instruction of a consultant was both disproportionate and premature and was not reasonable.