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Wain v Gloucestershire County Council & ors [2014] EWHC 1274 (TCC) - 02/04/14

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No sanction imposed on party for filing costs budget one day late. The Fourth Defendant ('D4') filed her costs budget six days before the costs management hearing as opposed to the requisite seven.

The Judge held that the breach was trivial; the Claimant had suffered no prejudice; the parties were able to deal with costs management at the hearing; and, unlike in Mitchell, there had been no disruption caused to the court's timetable. The Judge ordered, under CPR r.3.14, that the usual sanction for failing to file a cost budget should not apply.

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