This paper aims to summarise the responses to the Lord Chancellor's Department's consultation paper on a general pre-action protocol, issued October 2001. The paper proposed the development of a general protocol to be used in all disputes where no specific protocol exists, and included a draft protocol. The paper set out nine questions seeking views on the concept of a general protocol and comments on the draft.
103 responses were received. The largest number came from legal professionals - 29 from Solicitors, 8 from Barristers, 12 from representative organisations such as the Law Society and the Institute of Legal Executives. From the commercial business field there were 16 responses, from credit companies, debt collecting agencies and other businesses. 5 organisations that provide legal advice or protect consumer interests responded as did 4 trades unions, including the Trades Unions Congress. There were 5 responses from members of the judiciary, including the Association of District Judges.
Various other interested groups responded, including the Court Service, the Civil Justice Council, the Metropolitan Police Service and the Office of Fair Trading.
The chart below depicts the number of responses received broken down into categories of respondents. A full list of those who responded is annexed to this paper.
Overall 33% of respondents were in favour of the introduction of a general protocol. A further 26% recognised the need to avoid a proliferation of protocols but did not consider that a general protocol would be suitable in their area of work. However a significant proportion of respondents (19%) were opposed to the idea. The remaining 22% did not express a clear view on the desirability or otherwise of a general protocol.
Respondents were invited to give their views on the advantages and disadvantages of a general protocol. There were 92 responses to this question. Opinion was fairly evenly balanced with 70 advantages being cited and 69 disadvantages.
The main advantage of having a general protocol was seen to be that it would provide a uniform process that set out a structure and timetable to be followed. This would spread good practice and would act as a useful guide, particularly for litigants in person. This was the view of 39 respondents, including 19 members of the legal profession, 2 members of the judiciary, 2 businesses and 2 advisory groups.
A general protocol would also encourage the early settlement or resolution of disputes and help to dispose of meritless cases. In doing so it would be in harmony with the overriding objective of the Civil Procedure Rules. This was cited as an advantage by 22 respondents, of which 12 were from the legal profession, 1 from the field of ADR providers, 1 business, 1 local authority and 1 advisory group. A further 14 respondents (8 legal profession, 4 businesses, 1 advisory group and a Court Users' Association) said that a general protocol would lead to parties being informed of a potential dispute at an early stage and would encourage disclosure of information between parties.
Another major advantage put forward by 21 respondents was that having a general protocol would avoid a proliferation of protocols and fill the gaps left by existing protocols. Amongst others, this response was received from 12 members of the legal profession, 1 member of the judiciary, 1 ADR provider, 1 trades union, 1 business, and 1 advisory group.
Other advantages included: it will encourage the use of ADR methods; it will reduce the workloads on courts; it will provide certainty ; it will save costs and time; it will underline the courts' powers and offer sanctions for non-compliance; and it does not represent a major change to current pre-action behaviour.
However, 6 respondents said that they thought there would be little or no advantage to having a general protocol.
The disadvantages of introducing a General Protocol put forward by respondents were more varied. 31 respondents, including 19 members of the legal profession, 1 member of the judiciary and 5 businesses concerned with the credit industry or debt collection, expressed their concern that the protocol would be too general to be of practical use.
The reasons given were that the general approach would mean that the protocol cannot give sufficiently clear guidance - for example, it cannot be specific about the disclosure requirements for each type of dispute. The general guidelines it contains might not be appropriate for all circumstances and, therefore, the protocol would need to be modified for all but the most straightforward disputes. This in turn would lead to confusion and the protocol might be applied inappropriately and used when a specific protocol is more suitable.
Respondents also commented on the difficulty of devising a "one size fits all" protocol that caters equally for litigants in person dealing with a low value claim and complex commercial disputes concerning millions of pounds.
A general protocol was also considered to be too inflexible to cover all types of disputes and did not allow sufficient scope for lawyers to use their discretion out of fear of the imposition of costs sanctions for non-compliance. This was the view of 10 respondents, including 6 solicitors and 1 business concerned with the credit industry.
9 respondents, 7 of whom are members of the legal profession, considered that the introduction of a general protocol would add to costs and, therefore, conflict with the overriding objective of dealing with disputes in a way that is proportionate to the issue at stake.
Another disadvantage of a general protocol put forward by 16 respondents was that it would be an additional bureaucratic burden that would lead to delay. This is in contrast to specific protocols which clearly identify the information that should be disclosed and the essential issues, and, therefore, speed up the process. In particular it was thought that the timescales in the general protocol would result in an unnecessarily prolonged process in debt cases. Amongst others, this response was received from 7 members of the legal profession, 1 member of the judiciary, and 3 businesses concerned with the credit industry.
A significant number of respondents,13, mainly commercial credit businesses, expressed concern about whether the general protocol would be suitable for debt disputes in any event. In particular there were concerns that the protocol conflicted with existing legislation, notably the Consumer Credit Act 1974 and the Late Payment of Commercial Debt (Interest) Act 1998, and other Government initiatives and European Union Directives. Similarly, a general protocol might not be welcomed by bulk issuers of debt claims.
A general protocol, because of its lack of specific guidelines, was thought to be too complex to be operated successfully by litigants in person - 9 respondents made this point, 3 advice agencies and 3 members of the legal profession. There were also concerns about how unrepresented parties would be made aware of the existence and requirements of a general protocol.
A further disadvantage, cited by 6 respondents, was seen to be that a general protocol would discourage the creation of further specific protocols. This was the view of 4 members of the legal profession, 1 ADR provider and 1 trades union. One respondent commented that "Pre-action protocols are successful because they are tailored to specific types of cases".
Some respondents felt that the proposal for a general protocol did not add anything of significant value to the current provisions within the Protocols Practice Direction. Others commented that, for a general protocol to be workable, judges must be seen to enforce it. Otherwise there is a real danger that it may be ignored.
Respondents were also asked to consider the scope of the protocol. There were 60 responses to this question and again opinion was evenly divided.
29 respondents agreed that the protocol should apply to a wide range of cases regardless of complexity or value. Responses were received from 11 members of the legal profession, 2 members of the judiciary, 7 businesses concerned with the credit industry, 2 advice providers, 1 ADR provider and 1 local authority.
31 respondents, including 19 from the legal profession, 5 businesses concerned with the credit industry, 1 advice provider and 1 local authority, took the opposite view. Such a wide scope was criticised as being impractical since different disputes require different approaches.
A variety of arguments were put forward as to how and why the scope of a general protocol should be limited.
It was suggested that a general protocol would not be appropriate for small value claims with a value of less than £5,000. It would be contrary to the overriding objective of proportionality to expect the same detailed procedure for a straightforward debt collection with a value of £1,000 and a debt collection with value of £200,000 - or a complex neighbour dispute. As well as introducing disproportionate costs a general protocol would also cause unreasonable delays in lower value claims. These comments were received from 12 respondents, including 4 from the legal profession, 3 from the credit industry, 1 advice agency and 1 local authority. Conversely, 3 respondents, all members of the legal profession, thought that a general protocol should not apply to high value claims.
Respondents also suggested that a general protocol should be restricted to small claims and fast track cases; should only apply to represented parties and that separate guidance be provided for litigants in person.
Comments were invited on the proposed draft protocol that was contained in the Consultation Paper. Respondents were asked to consider the requirements for disclosure, the approach regarding expert evidence and the example letters set out in the draft protocol.
The consultation paper asked whether the guidance contained in the draft protocol is clear. 79 respondents answered this question. A clear majority - 56 respondents, including 24 from the legal profession, 3 members of the judiciary, 11 businesses, 3 trades unions, 2 local authorities, 1 advice provider and 1 ADR provider - thought that it was, but 24 of those qualified their answers.
9 respondents questioned how helpful the guidance would be for litigants in person and raised concerns about how unrepresented complainants would be made aware of the existence of the protocol. Suggestions were made for amending and clarifying the protocol so as to avoid legal jargon. For example, wording such as "acting reasonably" and "exchanging relevant information" could be open to different interpretations between solicitors and litigants in person.
3 respondents thought that the section dealing with alternative dispute resolution should be expanded. It was suggested that the protocol should refer to the leaflet "Alternatives to Court", available from the Legal Services Commission, and provide further guidance on how to find an ADR provider.
Some respondents considered that the text was confusing on what is, and what is not, part of "The Protocol". They commented on the need for clarity since this may well have implications if costs sanctions need to be considered by the court at a later date. The section about varying the protocol also needed expanding, for similar reasons. The flexibility for altering, by agreement, the timetables set out in the protocol would create a grey area which might prove difficult for the court to take account of in considering sanctions. 2 respondents suggested that, where the protocol was not considered appropriate, reasons should be raised with the other side in correspondence at an early stage.
Respondents also put forward a number of suggestions for ways in which the protocol could be amended or where further guidance would be helpful. For example, references to specific protocols; minimise the references to other Rules and instead reproduce the text; avoid the use of the word "dispute".
13 respondents thought that the guidance was not sufficiently clear, for similar reasons to those outlined above. The main concern being that the draft protocol would be confusing for litigants in person to understand. 3 respondents commented that the guidance was too general to be of practical use, and in any event, added little of value to what is already contained in the Protocol Practice Direction.
Respondents also suggested that the protocol should be submitted to the Plain English Campaign, to ensure its clarity.
The consultation paper asked whether any difficulties were seen with the disclosure requirements set out in the protocol. 69 responses were received to this question. 24 respondents, including 13 from the legal profession, 1 member of the judiciary, 3 businesses, 1 local authority and 1 advice provider, thought that this section posed no difficulties. The remaining 45 expressed a number of concerns about the requirements, although of those, 13 had answered "no" to the question. The chief concerns are set out below.
17 respondents, including 7 from the legal profession, 1 member of the judiciary, 2 advice providers, 1 business and 1 ADR provider, commented on the need for further guidance and clarification. It was recommended that the requirements for disclosure be clarified and restricted to the fundamental documents, with clear guidance on what and when disclosure should take place, including guidance on service of correspondence and the risks of costs sanctions. One respondent suggested that disclosure should be limited to those documents that a party would be entitled to compel the disclosure of through a Court Order. It should also be stressed that "all relevant documents" includes documents that may not be supportive of the case.
In particular it was thought that litigants in person would require further guidance on disclosure. The word "disclosure" is a term common to lawyers but not to the general public. Concern was expressed that unrepresented parties might be pressurised, through fear of penalties, into disclosing inappropriate documents. It was also suggested that the protocol contain further guidance on how to make a pre-action disclosure application to the court.
One respondent commented on the need to make it clear that there are some documents that parties are not entitled to ask for, although recognising that it would be impossible to provide a comprehensive list within a general protocol.
13 respondents raised concerns about confidentiality issues. It was suggested that the protocol should contain an enforceable prohibition against using disclosed documents other than for the purpose of resolving the dispute. The protocol also needed to be strengthened to make it clear that "fishing expeditions" would not be tolerated. Amongst others, these concerns were raised by 9 members of the legal profession, 2 businesses and 1 advice provider.
15 respondents, including 6 from the legal profession, 2 members of the judiciary, 5 businesses and 1 advice provider, commented on the need for the protocol to reflect the overriding objective of the Civil Procedure Rules in respect of proportionality. The disclosure requirements were not suitable for the typical small claims dispute with a value of less than £5,000. It was pointed out that, since part 31 of the Civil Procedure Rules does not apply to these types of dispute, some further clarification would be required.
It was also suggested that the protocol should draw a distinction between a litigious dispute and debt collection, where an invoice will already have been sent. Financial institutions, especially bulk issuers, would be put to enormous unnecessary expense if they were required to disclose documents with the enquiry letter since in the majority of cases this information would already have been sent to the other side.
Other concerns raised were: parties may be unfairly penalised if they fail to comply, since it is not always easy to identify what documents should be disclosed at the early stages of a dispute; arguing over what should be disclosed may give rise to further dispute or satellite litigation.
It was also suggested that the disclosure requirements should mirror those contained in the Personal Injury protocol and/or the Construction and Engineering protocol.
The consultation paper asked whether there were any practical difficulties which might arise from the approach set out in the protocol on expert evidence. Comments on this question were received from 61 respondents, of which 35 considered there were difficulties and 27 considered there were none. Respondents also suggested amendments to the draft and highlighted where further clarification could be useful.
The following difficulties were identified.
The draft protocol appeared to imply that in the majority of disputes, a joint expert should be instructed. This was not consistent with the Civil Procedure Rules, or with other existing protocols. Joint experts are not appropriate in all disputes. Indeed, the use of joint experts is rare in high value multi-track cases, especially in the Commercial Court. This point was made by 6 respondents, all members of the legal profession.
5 respondents - 3 members of the legal profession, 1 advice agency and a Government Department - thought that the approach set out in the protocol would cause confusion, particularly for litigants in person. Conversely, 1 respondent commented that the approach was geared to simple disputes and would not be appropriate in more complex cases.
The protocol, as drafted, might lead parties to believe that they must use a joint expert, which would increase costs unnecessarily. In any event the costs of obtaining a joint expert's report might outweigh any potential benefits, particularly since there were no guarantees that, if the matter did proceed to litigation, the court would allow such costs to be recoverable. This was the view of 3 members of the legal profession.
2 respondents, both from businesses concerned with the credit industry, thought that use of a single joint expert and the time periods suggested in the protocol could cause delay. This would be a significant problem if the dispute concerned perishable goods.
The approach set out in the protocol was thought to be an unnecessary extra convolution by 2 respondents - 1 member of the legal profession and 1 business concerned with the credit industry.
Other difficulties identified were: the protocol could encourage satellite litigation; and, the protocol does not add anything to the guidance on the use of experts that already exists within the Civil Procedure Rules.
A number of suggestions were put forward, by 14 respondents, for amendments to this part of the draft protocol. (8 members of the legal profession, 1 member of the judiciary, 3 advice providers, 1 Government Department and 1 local authority.) The suggested amendments are listed below.
The protocol should make a clear distinction between a joint agreed expert and a single joint expert and reflect the decision of the Court of Appeal in Carlson v Townsend concerning the disclosure of an agreed expert's report.
The response time to accept or reject a proposed expert's report should be 14 days from the expiry of the initial 21 day response to the letter of enquiry. This is consistent with the Personal Injury Pre-Action Protocol. That said, one respondent thought that the response time should be reduced to 7 days.
The information contained in Annex C would be better placed in the main body of the text.
Further consideration needed to be given to this part of the protocol in respect of disputes which would be likely to be allocated to the small claims, since part 35 of the Civil Procedure Rules does not apply to such cases.
All letters about the choice of an expert should be copied to insurers, since they have ultimate financial liability.
The number of experts put forward for approval should be limited to three and reasons should be given for rejecting any of them.
Costs liability could follow the expert's findings.
The section dealing with experts would be the ideal place to include a reference to using neutral evaluation as a way of moving towards settlement of the dispute without going to court.
The annex could include a reference to obtaining advice from providers listed in the Community Legal Service Directory. This would be especially helpful for litigants in person, who may have difficulty in knowing when it is appropriate to instruct an expert, or need help in finding one.
Respondents also highlighted those areas where the draft protocol would benefit from some clarification.
7 respondents (including 1 member of the judiciary, 1 ADR provider, 2 members of the legal profession and 1 advice provider) suggested that the protocol should make it clear that experts should only be instructed where there was a genuine need to do so. It should clearly emphasise that a court may not use the expert's report and that costs are not always recoverable.
Further guidance was required on instructing an expert in the pre-litigation period, including how to find one and, where necessary, obtaining the permission of the court. This comment was received from 3 respondents, 2 members of the legal profession and 1 advice provider.
The protocol should make it clear that instructions and further questions to joint experts, and the responses, should be copied to all parties. 3 respondents made this point, 2 trades unions and 1 member of the legal profession.
One respondent thought that Annex C was unnecessary, while another thought that paragraph 6 of the Annex might be confusing for litigants in person and so require further expansion. Both comments from members of the legal profession.
The Association of District Judges thought that the protocol needed strengthening to ensure that parties were made aware that there is a real risk of sanctions being imposed if a court decides that there has been no serious attempt to agree an expert.
1 member of the judiciary suggested that the protocol should emphasise that questions to experts should be for clarification only.
Respondents were invited to give their view on the example letters of enquiry and response. In particular whether they were thought to be suitable, was the coverage adequate and were the proposed time limits appropriate. 78 respondents replied to these questions, including 3 members of the judiciary, 39 from the legal profession, 13 businesses, 3 advice providers, 3 trades unions, 2 local authorities and 1 ADR provider.
Overall the majority of respondents thought that the example letters would not be suitable. Of the 66 respondents, 29 thought that both letters were unsuitable, 8 highlighted difficulties with the enquiry letter and 4 did not like the letter of response. The responses demonstrated that any attempt to provide default letters within the protocol would be problematic, and one respondent described it as a "fruitless exercise". If example letters were to be provided it should be made clear that they were only examples and that they would need to be adapted accordingly. A number for respondents suggested that it would be preferable simply to include a checklist of key general requirements.
Concerns were also expressed that the proposed letters were open letters, yet were encouraged to include proposed settlement offers that are usually made "without prejudice". It was suggested that the general protocol should mirror the Professional Negligence Protocol and make it clear that settlement offers should be contained in a separate "without prejudice" letter. It was also thought that this point might be confusing for unrepresented parties.
Respondents also suggested that the letters could invite a dispute and might encourage delays, particularly in matters concerning debt.
Only 32 respondents commented on whether they thought the coverage in the example letters adequate. Of those, 27 made suggestions for what else should be included. It was thought that the Enquiry Letter should set out clearly the implications if the other side failed to respond - that proceedings would be issued - and include a reference to the possibility of costs sanctions. A copy of the protocol should be sent with the Enquiry Letter. This was especially important if the other side was unrepresented, since they might not be aware of the existence of the protocol. The letter should also reflect the hope that the matter could be settled without recourse to litigation and an offer to attempt ADR.
It was suggested that the Letter of Response should include a monetary offer to settle, either by a fixed date or by instalments. The protocol should also make it clear that the Letter of Response should address all the points raised in the Enquiry Letter.
47 respondents commented on the proposed time limits for acknowledgement and response. A clear majority, 29, thought that the time limits were too generous, particularly in debt cases. However, there was no clear consensus of what would be considered a reasonable time limit. Some respondents added that in certain types of disputes the time limits would be too short.
Only 21 respondents commented on whether there should be scope within the protocol for the time limits to be extended. Although two thirds of those thought that the protocol should allow for the time limits to be extended, concerns were expressed that this could be used as a delaying tactic and could be open to abuse. One respondent commented that litigants in person might be reluctant to refuse any request for an extension because of the fear of appearing unreasonable and so attracting costs sanctions.
Respondents were asked whether they considered the suggestion that there be a period of reflection and consideration was helpful and whether any difficulties were expected in practice. Responses were received from 73 respondents, including 32 from the legal profession, 2 from the judiciary (including the Association of District Judges), 17 from businesses, 4 from advice providers, 2 from local authorities, 2 from trades unions and 1 ADR provider. However, not all responses gave a clear indication whether they supported or opposed the idea of the period of reflection, but simply identified difficulties or made suggestions for further guidance.
29 respondents thought that the period of reflection would be helpful, including 11 members of the legal profession, 1 member of the judiciary, 6 businesses, 1 trades union and1 local authority.
26 respondents, from among others 11 members of the legal profession, the Association of District Judges, 10 businesses and 1 local authority took the opposite view.
The major practical difficulty identified by 26 respondents was, overwhelmingly, that it would lead to delays, either unwittingly or deliberately. This was chiefly the concern of businesses (10), but was also cited by 11 members of the legal profession and 2 advice providers. One respondent commented that any delay would only increase the amount of interest due on a debt, which might not be in the debtor's best interests. It was also suggested that, to avoid delay, there should be a mechanism for parties to agree whether this should apply.
15 respondents, including 11 members of the legal profession and 2 advice providers, thought that the proposed period of reflection would benefit from setting out specific time limits. There was no consensus of opinion as to how long this should be. One respondent suggested no more than 14 days, another that the parties should agree between themselves, but in any event no longer than 28 days.
5 respondents suggested that this paragraph should be expanded to further promote and encourage the use of ADR, since this would seem a logical stage in proceedings for parties to consider it.
4 respondents thought that further guidance was necessary, but did not specify what form that guidance should take.
Other difficulties identified were: persuading the complainant that this would not add to costs; would allow the potential defendant time to move away; this would only work if both parties were ready to co-operate, which was unlikely at this stage; would only work if both parties are experienced litigators; and, needed to clarify the position if the statute of limitations applied.
Respondents were asked if there were any particular classes of proceedings or types of circumstances where the protocol should not apply. There were 79 responses to this question and an overwhelming majority, 67, highlighted areas where it was considered the protocol should not apply.
27 respondents, including 12 businesses, 9 from the legal profession, 1 ADR provider, 1 advice provider and 1 local authority, thought that the protocol should not apply to commercial or consumer debt disputes. 13 of these also included mortgage possession proceedings and disputes concerning the return of goods. 3 respondents said that the protocol should not apply to proceedings in the Commercial Court.
The protocol was thought not to be appropriate when the claimant needed an immediate remedy, such as an emergency injunction, or where the limitation period was close to expiry. This was the view of 24 respondents, including 14 from the legal profession, 3 businesses, 3 advice providers and 1 ADR provider. 2 respondents added that the protocol should not apply where summary judgment was available. Disputes which involve a choice of, or challenge to, jurisdiction were also held to be inappropriate.
7 respondents suggested that the protocol would not be suitable for small claims (those with a value of less than £5,000) particularly since the majority of such claims would involve litigants in person.
A number of respondents indicated types of proceedings where compliance with the general protocol would not be consistent with existing statutory requirements. For example: Consumer Credit Act 1974; Stop Now Orders (EC Directive) Regulations 2001; Fair Trading Act 1973; and, Competition Act 1998. For similar reasons the protocol was thought to be unsuitable for proceedings concerning the recovery of Tax, Habeas Corpus, insolvency or director's disqualification.
Respondents also suggested types of proceedings that would benefit from having a specific protocol. These included intellectual property disputes, disease and illness disputes and claims concerning road traffic accidents.
Numerous other exemptions from the general protocol were put forward. Ranging from: disputes where there was no bona fide defence; discrimination disputes; Landlord and Tenant disputes; Human Rights disputes; and, Public law cases.
The responses to the questions, and other comments received, have highlighted the difficulties in producing successfully a protocol capable of applying to all types of dispute. Although respondents acknowledged the need to avoid a proliferation of protocols, it is equally clear that the proposed draft would be too general and would be likely to lead to confusion and unnecessary delay.
The diverse requirements of specific types of disputes and the absence of any consensus as to how to amend the proposed protocol means that it is now believed that any further attempts to develop a general protocol would be unlikely to be successful.
However, the concerns that led to the proposal of a General Protocol remain. It is still considered desirable that parties in all types of dispute should follow the basic principles of a pre-action protocol, that they act reasonably in exchanging information and documents at an early stage and generally seek to settle the dispute without recourse to litigation. Although it is now clear that a General Protocol, applicable to all types of disputes, is too ambitious, it still leaves the question of how to influence the behaviour of parties outwith court proceedings, and to do so in a way that will avoid a situation where every type of dispute has its own specific protocol.
It has, therefore, been decided to explore how to build on the existing provisions within the Civil Procedure Rules to devise a mechanism that will not only provide a uniform process but will also underline the courts' powers and offer sanctions for non-compliance.
Advice Services Alliance
Phillip Bliss Aliker
Alliance & Leicester plc
Neil Andrews
Ashurst Morris Crisp
Association of British Insurers
The Association of District Judges
Association of Personal Injury Lawyers
Chris Baker
Baker & McKenzie
The Bar Council's Law Reform Committee
Mark Barnes QC
Beacon Legal Services Limited
Blackburn with Darwen Borough Council
British Music Rights
Peter Browne
Caveat Emptor
CEDR Solve
Certificated Bailiffs Association
Chancery Bar Association
The City of London Law Society
Civil Court Users Association
Civil Justice Council
J M Clark
CMS Cameron McKenna
Commercial Bar Association
Consumer Credit Association
Consumer Credit Trade Association
Council of Mortgage Lenders
The Court Service
Credit Services Association
Department of Health
J J Dilger
Disability Rights Commission
Disqualification Unit of the Insolvency Service
DJ Freeman
DLA
Employment Lawyers Association
Environmental Law Foundation
Eversheds
Federation of Insurance Lawyers
Finance & Leasing Association
French & Co
Geoffrey Parker Bourne
Geoffrey Shindler
Green & Co
Professor David Hayton
Herbert Smith
Holborn and Westminster Law Society - Litigation Committee
His Honour Judge Holman
Immigration Law Practitioners' Association
Inland Revenue
The Insolvency Service
Institute of Credit Management
Institute of Legal Executives
Institute of Revenues Rating & Valuation
Intellectual Property Bar Association
The Intellectual Property Working Party of the Law Society
InterMediation
The Law Society
Legal Action Group
Leigh Day & Co
Master Leslie of the Queen's Bench
Liverpool Law Society
Lloyds TSB Bank plc
The London Authorities Trading Standards Consumer Advice and Education
Group
London Common Law and Commercial Bar Association
London Solicitors Litigation Association
Lovells
Lovetts plc
Manchester Law Society
Marks and Spencer Financial Services Limited
Metropolitan Police Services
S W Morris
Motor Accident Solicitors Society
Musicians' Union
National Association of Citizens Advice Bureaux
Northumberland County Council
Office of Fair Trading
Olswang
Andrew Park
Principal Registry of the Family Division
Senior District Judge of the Family Division
Property Litigation Association
Resolve UK Consultants Ltd
Richards Butler
Ridgeway Management Services Ltd
Rowe & Maw
Senior Costs Judge
Shadbolt & Co
Sheffield Citizens Advice Bureaux Debt Support Unit
Shoosmiths
Small Business Service
Supreme Court Group
Jeremy Sutcliffe
TBSEL
Thompsons
Peter Thompson QC
Trade Marks Patents and Designs Federation
Trades Union Congress
The Treasury Solicitor
Turner Broadcasting Systems
UNISON