Lloyds Developments Limited v Accor Hotel Services UK Limited [2026] EWHC 1238 (TCC)

The court carried out a summary assessment of costs. The paying party objected that the hourly rate charged for one fee earner exceeded the guideline rate for a grade C fee earner, and that the amount of his time should be reduced.

Mrs Justice Jefford accepted that the junior fee earner's charge should be reduced, and made the reduction sought, while making clear that it reflected the guideline rate rather than any criticism of the quality of his work. She declined, however, to reduce the time recorded by the senior grade A fee earners, because the more work done by a junior person the more supervision and checking is required from those above. Taken together the reductions came to a set figure.

The case is a practical illustration of how a court approaches guideline hourly rates on assessment: a junior earner's rate may be trimmed to the guideline, but that does not automatically justify cutting the senior time spent supervising the same work.

Mrs Justice Jefford made "a reduction of £7,000" to the junior fee earner's time while leaving the supervising time intact.