Professional litigant in person

Sisu Fund Ltd and others v Tucker and Spratt and others [2005] EWHC 2321 (Ch)

It was clearly established in London Scottish Benefit Society v Chorley (1883–84) LR 13 QBD 872 that a litigant in person cannot recover costs for his own time, except where that person is a solicitor. Although London Scottish and other authorities advocating the same principle were decided prior to the coming into force of the CPR, it would be contrary to the policy of the CPR, which was to reduce the costs of litigation, if the range of recoverable costs had been extended without clear and express provisions. Accordingly, a litigant in person, even if a professional, cannot recover in respect of his time spent other than on matters within his own professional expertise which would otherwise require the attention of an expert. Accordingly, an accountant who is a litigant in person could at most recover for work he had done himself, what the cost of obtaining the expert advice of an independent professional would have been but he is not entitled to recover the costs of general assistance to an expert in the conduct of litigation.