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Points of Dispute – Drafting for Detailed Assessment

Strategic, compliant and targeted Points of Dispute to reduce costs exposure.  Points of Dispute are the paying party’s primary tool for challenging a bill of costs. The quality and focus of the drafting will often determine whether a matter settles or proceeds to detailed assessment, and the level of reduction achieved. We act for insurers, local authorities and defendants across England & Wales in drafting Points of Dispute that target the issues most likely to influence the outcome.

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Urgent deadline? Speak directly to a costs specialist today.

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Why Points of Dispute matter

Points of Dispute define the scope of the dispute under CPR Part 47. They determine:

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  • which costs are challenged

  • how those challenges are framed

  • the issues the court will ultimately decide

 

Unfocused or generic Points of Dispute are far less effective in negotiation and at assessment.  Well-structured Points of Dispute allow:

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  • early identification of reduction opportunities

  • stronger negotiation positioning

  • improved outcomes at provisional or oral assessment

 

For a broader strategy overview, see:


→ How Paying Parties Challenge a Bill of Costs at Detailed Assessment.

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How we draft Points of Dispute

We prepare Points of Dispute that are:

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  • Targeted – focusing on the entries and issues most likely to carry weight

  • Structured – compliant with Precedent G and CPR Part 47

  • Strategic – linking individual challenges to proportionality and overall exposure

 

Our work typically involves:

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  • challenging hourly rates and fee earner grade

  • identifying duplication and unnecessary work

  • advancing proportionality arguments

  • challenging recoverability and scope

  • addressing procedural and compliance issues​

 

For more detail on the drafting framework, see:


→ Points of Dispute in Detailed Assessment

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Strategic approach to drafting

Effective Points of Dispute go beyond item-by-item challenges.  The strongest outcomes arise where:

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  • hourly rates

  • time claimed

  • delegation

  • overall totals

 

are linked to proportionality, conduct and the actual requirements of the litigation.

 

This approach frequently results in:

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  • early negotiated reductions

  • improved provisional assessment outcomes

  • stronger positioning if the matter proceeds to hearing


Case Study: £30,000 saving through targeted challenges

A Schedule of Costs of approximately £70,000 was served in a public liability claim.

Our Points of Dispute focused on:

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  • excessive Grade A fee earner time

  • duplication where Counsel had undertaken key work

  • disproportionate costs relative to damages

  • lack of breakdown in significant time entries

 

We also deployed procedural pressure and technical arguments.

Outcome:

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  • Costs reduced to approximately £40,000

  • Saving of around £30,000 (43%)

  • Contribution secured towards the Defendant’s own costs


Case Study: £15,500 claim reduced to £150

In a housing disrepair claim, a Bill of Costs of approximately £15,500 was served following discontinued proceedings.

We advanced:

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  • challenges to recoverability of pre-issue costs

  • procedural arguments arising from discontinuance

  • proportionality challenges

 

The matter proceeded through detailed assessment and further application.

 

Outcome:

  • Approximately £3,600 allowed on assessment

  • Net recovery reduced to around £150

  • Claimant’s position significantly worsened


Acting Nationally for paying parties

We act for insurers, local authorities and private defendants across England & Wales in:

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  • drafting Points of Dispute

  • detailed assessment proceedings

  • negotiation strategy following Replies

  • complex and high-value costs disputes

 

Early specialist input frequently leads to significant reductions before a matter reaches contested assessment.

For broader paying party support, see:


→ Challenge a Bill of Costs


Speak to a costs specialist

Points of Dispute must normally be served within strict time limits. Early advice can materially affect the outcome.

 

📞 Speak to a specialist: 01772 435550
📩 Email us

Specialist support for paying parties in contested costs

For urgent instructions or a same-day quotation for Points of Dispute, contact our paying party costs team or upload your papers for immediate review. An overview of our paying party services is available here.

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For urgent matters, you can upload your bill of costs to our portal for review.

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