Procter & Gamble Co v (1) Svenska Cellulosa Aktiebolaget SCA (2) SCA Hygiene Products Manchester Ltd [2012] EWHC 2839 (Ch) - 23/10/12

CPR r.36.2(2)(c) did not mandate that for a Claimant to make a valid Part 36 offer, he had to make the payment of his costs by the Defendant a condition of his offer. It meant that if a claimant sought his costs, he had to specify a period of not less than 21 days in which they were to be paid.