John Michael Sharp v Sir Maurice Victor Blank [2017] EWHC 3390 (Ch)

Court considers revision of a costs budget and the meaning of a "significant development"

Costs budgets cover costs to be incurred (not costs already incurred). PD3E para 7.6 provides that "Each party shall revise its budget in respect of future costs upwards or downwards, if significant developments in the litigation warrant such revisions ... The court may approve, vary or disapprove the revisions having regard to any significant developments which have occurred since the date when the previous budget was approved or agreed".

This case involved seven claims that were subject to a group litigation order and the claimants applied for a costs management order. Total budgeted costs amounted to just under £37 million. The defendants subsequently asserted that certain significant developments required them to revise their budget and the claimants refused to agree to the revisions.