PART 36
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By Nicola Laver
A part 36 offer under part 47 of the Civil Procedure Rules (CPR) which was made exclusive of interest was not valid. Newey LJ ruled in King v City of London Corporation [2019] EWCA Civ 2266 that it was not possible to make a valid part 36 offer exclusive of interest either generally or in the context of detailed assessment proceedings. However, he reached his conclusion reluctantly and said the issue merited consideration by the CPR committee. 18 December 2019