Practice – Costs. An appellant litigant in person who wilfully disclosed during a trial a 'without prejudice' letter containing an offer of settlement made by the respondent did so improperly in the circumstances of the case. The Court of Appeal, Civil Division, held that the judge had exercised his discretion correctly in making a wasted costs order against the appellant and ordering him to make an interim payment on sanction of the claim being struck out, and dismissed the appeal accordingly.