Costs – Assessment. The claimant applied for the detailed assessment of 15 bills of costs for which the parties eventually agreed a reduction of one fifth. Despite that, the costs master held that there were special circumstances under s 70(10) of the Solicitors Act 1974. Instead of awarding the claimant its costs, he ordered the claimant to pay the defendant 70% of its costs of the assessment. The claimant applied for permission to appeal. The Queen's Bench Division granted permission and allowed the appeal on the basis that the judge had used the incorrect approach. The effect of that error was that the normal one-fifth rule had to apply and it followed that the claimant was entitled to the costs of the assessment.