Jeremy Warner > 3PB > London

Jeremy Warner specialises in the intersection between medicine and the law. His practice spans personal injury, clinical negligence, inquests and the Court of Protection. He is regularly instructed in both multi-track and intermediate track litigation.

Prior to joining 3PB, he worked in-house at a leading personal injury law firm in London, where he developed both written and oral advocacy experience in multi-track personal injury and clinical negligence litigation.

In personal injury and clinical negligence law, Jeremy represents both claimants and defendants and is happy to accept work on a Conditional Fee Agreement. In Coronial Law and the Court of Protection, Jeremy is instructed by all Interested Persons and institutions including families, government bodies and local authorities. He is also currently on the Junior panel with the Government Legal Department and has been instructed by the Office of the Public Guardian, the Home Office and the Ministry of Justice.

The specifics of each of his practice areas are detailed below.

More generally, Jeremy also has a strong commitment to public legal education, having volunteered with the Schools Consent Project to deliver workshops on sexual offences law to secondary school students. He was awarded an Inner Temple scholarship to participate in a gender equality programme in Ghana and has also taught in Rwanda, worked as an English tutor in Shanghai, and worked on a vineyard near Rome.

He is also a keen cricketer and plays for the MCC and a team in London, having previously played for Dorset and Shane Warne’s first club in Melbourne.

He was named on Lady Chief Justice Carr’s Pro Bono Recognition list in 2026.

Personal Injury

Jeremy has appeared in both the County Court and High Court and has been instructed in a variety of hearings such as trials, CCMCs, pre-action disclosure applications, strike outs, relief from sanctions applications, and applications to resile across a variety of cases. He also has experience in enforcing third party costs orders further to Tescher v Direct Accident Management Limited [2025] EWCA Civ 733.

He has also made submissions on directions and budgeting in high value claims and has advocated before the Masters at the Royal Courts of Justice.

His experience includes:

Acting in a variety of personal injury related trials, including those involving allegations of fundamental dishonesty and s57 Criminal Justice Act 2015.
Advising on liability and quantum in personal injury claims relating to spinal fractures, chronic regional pain syndrome, hip fractures, facial disfigurement, supraspinatus tears, ophthalmic trauma, PTSD and stinger injuries.
Represented claimants with traumatic brain injuries, risk of epilepsy, acoustic shock and tinnitus.
Drafting schedules of loss for claimants who are employed and self-employed including those who are directors of companies with consideration of issues regarding separate legal personality.
Interim payment applications, including a recent multi-track application for a claimant suffering from functional neurological disorder and chronic regional pain syndrome where multidisciplinary treatment is sought.
Advising on strategy regarding provisional damages.
Multi-track applications and CCMCs, including a successful opposition to an application seeking to withdraw a pre-action admission in a multi-track acoustic shock case.
Advising on privity of contract and/or whether a duty of care was owed between an insurance company and its policyholder(s) in respect of the delay in investigating a subsidence claim causing psychiatric injury.
Drafting Advice and skeleton arguments for multi-track personal injury claims, including complex injury cases relating to the spectrum of Ogden disability, Smith v Manchester awards, and the nuances of claims involving future losses.
Advising on liability and quantum, drafting skeleton arguments and injunctions in the cross-cut between education, personal injury law, and abuse.
Fatal accident claims including dependency claims.
Advised on the scope of duty of care in tort with reference to the SAAMCO principles and Khan v Meadows [2021] UKSC 21.
Drafting pleadings in negligence, product liability, and cases under the Highways Act, Animals Act, employers’ liability, occupiers’ liability and road traffic accidents.
Acting in credit hire litigation, where he has been often praised by the judiciary for his pragmatic approach.
Striking out deficient pleadings.
Clinical Negligence
Jeremy gained experience as a clinical negligence paralegal and an in-house advocate before joining 3PB. Since being called, Jeremy has:
- Assisted in the settlement of a claim regarding the delayed diagnosis of non-small cell lung cancer, including the assessment of the claimant’s damages arising from reduced life expectancy in the context of multiple co-morbidities.
- Been instructed in relation to a stroke-related death following a patient’s discharge after a TIA and subsequent deterioration.
- Represented an executor in circumstances where the deceased passed away soon after suffering a witnessed fall at a care home.
- Drafted advice and a Schedule of Loss for a claimant who suffered significant scarring and incontinence due a delay in diagnosis of necrotising fasciitis.
- Been instructed to strike out defective pleadings in clinical contexts where no operative duty of care was owed and/or the cause of action was not properly identified.
- Advocated at an infant approval hearing in a claim where the Trust failed to remove a swallowed battery in accordance with its internal protocols.
- Delivered training to law firms on experts’ statistical fallacies when calculating reduction of life expectancy.
- Advised on secondary victim claims in the clinical negligence context before and after the abyss that was created by Paul v Royal Wolverhampton Trust [2024] UKSC 1.
- Drafted pleadings in birth injury claims and co-wrote an article with a senior member of chambers on material contribution, divisible injuries and hypoxic brain insult.
- Inquests
- Jeremy’s practice in coronial law includes acting in:
  - A three-day Inquest concerning the mis-categorisation of an ambulance call, which delayed treatment for cardiac arrest caused by an ST elevation myocardial infarction. He questioned an interventional cardiologist and multiple NHS Trust witnesses in a case where a prevention of future deaths report was ultimately issued against the Trust.
  - A neonatal death Inquest involving sepsis and Group A Streptococcus. Jeremy drafted submissions on Article 2 ECHR and the application of the systems duty, and represented the family at the Pre-Inquest Review Hearing and in subsequent written submissions.
  - A clinical inquest concerning multi-organ failure secondary to an infection due to and caused by infective endocarditis. It related to issues regarding in-dwelling catheters and pseudomonas.
  - A care home inquest regarding an unwitnessed fall. The inquest centred on the care home’s falls risk assessment.
  - Proceedings relating to a suicide at a drug rehabilitation centre. The case relates issues relating to mental health and risk management and Jeremy recently attended the PIRH and provided written submissions to assist the coroner in relation to the scope of the Inquest, relevant witnesses and evidence.
  - Proceedings regarding a drug related death whereby causation was an issue due to the deceased’s asymptomatic heart defect. Jeremy represented a GP.
  - Proceedings regarding a stroke related death when the patient suffered a TIA, was discharged and subsequently deteriorated.
  Jeremy has also:
  - Drafted written submissions under s7(2) and (3) of the Coroners and Justice Act 2009 requesting a jury for a three-day Inquest on behalf of his then pupil supervisor, an Assistant Coroner. This sensitive case involved suicide whereby there was reason to suspect the death arose from the act or omission of a police officer.
  - Advised on strategy and the practical and legal distinctions between Judicial Review and applications under section 13 Coroners Act 1988.
  - Undertaken further advocacy training from both coroners and a leading Silk.
    Providing training to law firms and paramedics on witness statements and evidence in coronial proceedings.
  - Court of Protection
  - In Care and Community Law, and the Court of Protection, Jeremy Warner has:
    - Been instructed in contested hearings regarding disputes over P’s best interests including questions of residence and format of care provision.
    - Acted in property and financial affairs disputes regarding the revocation of Lasting Powers of Attorney when P’s attorneys breached their fiduciary duties.
    - Acted in property and financial affairs disputes regarding Lasting Powers of Attorney when P was argued to have lacked capacity at the time of execution.
    - Acted in health and welfare disputes relating to the deprivation of liberty of a young person with complex PTSD
    - Drafted a position statement for a local authority regarding educational provision for P, a young person with autism and global development delay.
    - Been instructed in challenges under s.21a Mental Capacity Act 2005 concerning deprivations of liberty safeguards
    - Represented a vulnerable client in a dispute between a care home seeking her eviction. The case involved complex medical needs including epilepsy and reliance on total parenteral nutrition, and focused on whether eviction was compatible with her safety.
    - Costs
    - Jeremy Warner has a strong costs practice and has attended several CCMCs and been given delegated authority to negotiate on budgets in both the County Court and High Court. He has appeared in front of the Masters at the RCJ (most recently in front of Master Sabic KC) on various occasions with budgets valued in the hundreds of thousands.
      
      He has also advocated in a number of costs disputes where CPR 27.14(2)(g) is engaged. He has drafted skeleton arguments on the same. He has also experience in general summary assessment of costs at the end of interim applications (which do not attract fixed costs) and where Part 36 indemnity costs are engaged.
      
      He has also attended multiple costs hearing relating to third party costs order pursuant to CPR 46 and Tescher v Direct Accident Management Limited [2025] EWCA Civ 733.

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