25 February 2016
Milton Keynes NHS Foundation Trust v Hyde [2016] EWHC 72 (QB), [2016] All ER (D) 158 (Feb)
The Queen’s Bench Division dismissed the defendant NHS’s Trust’s appeal against a decision of a master in relation to costs holding that where a party had exhausted the costs, that could be claimed under a Legal Aid certificate so that it was ‘spent’, it could in principle establish a discharge by conduct in the same manner as certificates in which all of the work up to a limitation of scope had been carried out and accordingly, ss 10(1) and 22(2) of the Access to Justice Act 1999 had been not been contravened.
