Thomas Hadley (A Protected Party By His Litigation Friend Laura McCarry) v Mateusz Przybylo [2023] EWHC 1392 (KB)
![Willis v GWB Harthills LLP & Others [2025] EAT 79, His Honour Judge James Tayler, Rule 76 Employment Tribunal Rules 2013, Rule 84 Employment Tribunal Rules 2013, Rule 74 Employment Tribunal Rules 2024, Rule 82 Employment Tribunal Rules 2024, Stage 1 Threshold Conduct, Stage 2 Discretionary Decision, Stage 3 Quantum Decision, Ability to Pay, Costs Discretion, Unreasonable Conduct, Capital Assets in Costs Assessment, Family Home Valuation, Equity Release, Joint Ownership of Property, Detailed Assessment, Standard Basis, Profit Share Entitlement, PHI Payments, Costs Capping, Broad-Brush Assessment, Means Assessment, Proportionality of Costs, Discretionary Factors in Costs Awards, Effect on Third Parties, Honesty of Party, Costs Application Principles, Conduct of Proceedings, Stage 4 Bowel Cancer Context, Zoopla Valuation Evidence, Stage 3 Costs Quantum, Shields Automotive Ltd v Greig, Howman v The Queen Elizabeth Hospital Kings Lynn, Jilley v Birmingham and Solihull Mental Health NHS Trust, Arrowsmith v Nottingham Trent University [2012] ICR 159, Vaughan v London Borough of Lewisham (No 2) [2013] IRLR 713, Doyle v North West London Hospitals NHS Trust, County Court Detailed Assessment, Costs Decision in Employment Tribunals](https://tmclegal.co.uk/wp-content/uploads/2025/06/Shutterstock_351049592-80x80.webp)
Thomas Hadley (A Protected Party By His Litigation Friend Laura McCarry) v Mateusz Przybylo [2023] EWHC 1392 (KB)
10. I accept the Defendant’s argument at hearing that it is a general principle that ‘costs’ are legal costs which are incurred in the progression of litigation. They may be pre-action for example or they may be reasonably incurred but found in hindsight not to be useful yet such costs can still be ‘progressive’ even if they rule out some things which are then not pursued. But costs which are inherently non-progressive are not in my judgment ‘costs’ properly claimable in a budget between the parties It is not unusual in assessing a bill of costs to disallow items with the brief statement ‘non-progressive’ for example and it seems to me that if costs fall into that category then they are not suitable for inclusion in a budget.
