LEARNING CURVE (NE) GROUP LIMITED V LEWIS & PROBERT [2025] EWHC 2491 (Comm)

Following a £5.2m judgment matching their Part 36 offer, defendants mounted comprehensive challenges to avoid Part 36 consequences under CPR 36.17—from offer validity to enhanced interest rates to payment on account percentages. The court rejected each argument, reinforcing that escaping Part 36 consequences requires clearing a “formidable obstacle.”