No analogy with Part 36 when considering effect of Calderbank offer under costs discretion in CPR 44.2 (Court of Appeal) | Practical Law
In Coward v Phaestos and others [2014] EWCA Civ 1256, the Court of Appeal considered a costs appeal by the unsuccessful claimant, primarily on the basis that the judge below had failed to take proper account of a Calderbank offer that he had made.