Non-party costs

Topic

Non-Party Costs

Non-party costs refer to costs orders made against individuals or entities who are not directly a party to the litigation but have an involvement or interest in the case. Such orders are exceptional and are made under specific circumstances where the non-party's actions or involvement justify holding them financially responsible for some or all of the litigation costs. The underlying principle is that the court can exercise its discretion to prevent injustice and ensure fairness, particularly where the non-party has acted improperly or has financed the litigation for their own benefit.

Circumstances Justifying Non-Party Costs Orders

Non-party costs orders may be considered in various situations, including:

  • Control or Funding of Litigation: A non-party who funds or controls the litigation may be liable for costs, especially if they stand to benefit from the proceedings. This can include directors or shareholders of a company, insurers, or other financial backers who have a significant interest in the outcome.
  • Improper Conduct: If a non-party engages in improper conduct that causes unnecessary costs or delays, the court may order them to pay costs. This can occur if the non-party acts in bad faith, abuses the process, or interferes with the proper administration of justice.
  • Nominal Claimants or Defendants: In cases where the named parties are mere 'fronts' or 'nominal parties' with no real interest in the proceedings, and the actual interested party is not on record, a non-party costs order may be made against the real interested party.
  • Indemnity or Contractual Obligations: Sometimes, contractual arrangements may specify that a non-party will indemnify a litigant for costs. In such cases, the court may enforce these provisions by ordering the non-party to pay the costs.

The court's discretion to order non-party costs is governed by case law and the overriding objective of the Civil Procedure Rules to deal with cases justly. Key considerations include:

  • Fairness and Justice: The court must ensure that making a non-party costs order is fair and just in the circumstances. The non-party's connection to the litigation, the benefit derived from it, and the conduct exhibited will all be scrutinized.
  • Opportunity to be Heard: Before making a non-party costs order, the court must ensure that the non-party has had an opportunity to be heard and to present their case. This is a fundamental principle of natural justice.
  • Direct Involvement: The degree of the non-party's involvement in the case is critical. The court will assess whether the non-party played a significant role in controlling or directing the litigation.
  • Prejudice to the Non-Party: The potential prejudice to the non-party will be considered, including whether they had notice of the risk of a costs order being made against them and the financial impact such an order might have.

Example - Non-Party Costs Order

Scenario:

Company A, a small business, is sued by Supplier B for breach of contract. The litigation is funded and controlled by a major shareholder, Mr. X, who stands to gain personally from the outcome. Mr. X directs Company A's legal strategy, and the court finds that his decisions have unnecessarily prolonged the proceedings and increased costs.

Costs Order Decision:

After the trial, the court finds in favor of Supplier B and considers the application for costs. The judge, noting Mr. X's significant control and financial interest, orders him to pay part of Supplier B's costs, reasoning that he had effectively directed and benefited from the litigation despite not being a named party.

Outcome:

The court concludes that it is fair and just for Mr. X to bear some of the costs, given his substantial involvement and the benefits he sought to derive from the case. This non-party costs order ensures that Mr. X, rather than Company A alone, bears financial responsibility for the consequences of the litigation.

Challenges and Appeals

Non-party costs orders can be challenged or appealed. The non-party may argue that the order was unfair or that they were not adequately involved in the litigation to justify such an order. The appeal court will review the lower court's decision to ensure that the discretion was exercised properly and in accordance with legal principles.

Conclusion

Non-party costs orders are a tool used by the courts to ensure fairness and justice in the allocation of litigation costs. While they are not common, such orders are critical in cases where a non-party has a significant influence or interest in the proceedings. Understanding the circumstances and legal principles governing non-party costs orders is essential for anyone involved in litigation, as these orders can have substantial financial implications.

SQE2

Specification

Explore