Important Court of Appeal decision on the requirements for bills of costs

News & Judgments
11 May 2022

On 10 May 2022, the Court of Appeal handed down its decision in AKC v Barking, Havering & Redbridge University Hospitals NHS Trust [2022] EWCA Civ 630, which provides important guidance on the information bills of costs (both paper and electronic) must include. The Appellant’s appeal against the decision of Steyn J [2021] EWHC 2607 (QB) was dismissed.

In relation to the paper bill of costs, the Court of Appeal held that:

  • While it is desirable that fee earners should be named in paper bills, they do not have to be ([38]).
  • The description of each fee earner’s status should include any professional qualification and, unless the SCCO grade is given, their number of years of post-qualification experience ([39] to [41]).
  • A receiving party is not required to specify any qualifications or post-qualification experience of a fee earner where none is relied on ([40]).

In relation to the electronic bill of costs, the Court of Appeal held that:

“any electronic bill, whether in Precedent S spreadsheet format or any other spreadsheet format, must include the name, the SCCO grade and, in so far as it adds anything to the grade, the status of each fee earner except possibly in so far as the receiving party’s solicitors may have outsourced work to an agency” ([50]).

Robert Marven KC acted for the successful Respondent.  Matthew Waszak was junior Counsel for the Appellant.

Related People

Robert Marven KC

Call: 1994 Silk: 2018

Matthew Waszak

Call: 2012



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