In Ogiehor v Belinfantie [2018] EWCA Civ 2423
the Court of Appeal upheld the trial judge’s decision to make a wasted costs order against a litigant in person who had deliberately disclosed to the trial judge that the defendant had made a without prejudice save as to costs offer.
The disclosure, which the judge had tried to prevent, caused the trial to be adjourned.
The judge ordered the claimant to pay the wasted costs, and ordered that he make an interim payment of £10,000 within four months in order for the case to continue.
The Court of Appeal upheld the order, applying the three-stage test in
Ridehalgh v Horsefield [1994] Ch.205 CA
and noting that the standard of compliance with the rules to be expected of litigants in person as set out in
Barton (Appellant) v Wright Hassall LLP (Respondent) [2018] UKSC 12
