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2026 IEHC 337

Obsah (35)§4§5§6§7§8§9§11§12§13§14§16§19§20§21§22§23§24§26§27§28§29§30§32§33§34§36§38§40§41§42§45§46§3§105§31

[2026] IEHC 337 THE HIGH COURT Record No. 2026 656 JR BETWEEN (1) ANN NOLAN, (2) ELIZABETH NOLAN, (3) JOAN NOLAN, (4) RICHARD NOLAN, (5) PATRICIA NOLAN, (6) SALLY NOLAN and (T) QUEST CAPITAL TRUSTEES

hearing before me yesterday afternoon and for part of this morning.

  1. In summary, it would appear that the Chief Legal Costs Adjudicator has indicated that the adjudication will proceed notwithstanding documentary deficiencies notified to the Chief Legal Costs Adjudicator and the notice parties, by way of two Form 9s dated 20 March 2026 and 06 May
  2. It is the applicant’s case inter alia that they cannot properly engage with the adjudication on a fair and informed basis in circumstances where the bill of costs does not conform with O.99, r.23 of the Rules of the Superior Courts, hereinafter referred to as the “RSC”. Secondly, that the Chief Legal Costs Adjudicator should not have proceeded to indicate that an adjudication will take place tomorrow without directing that the bill of costs may be accepted for adjudication notwithstanding lack of conformity, pursuant to the provisions of O.99, r.6

(7). Further, the Chief Legal Costs Adjudicator failed to take into account the guidelines published by his office in September 2021, pursuant to the provisions of s.142 of the Legal Services Regulation Act 2015, hereinafter referred to as “the Act”.
  1. In addition to seeking leave to issue judicial review proceedings, the applicants seek a stay on the adjudication proceeding tomorrow, pending the full determination of the judicial review proceedings. The statement of grounds is dated 12 May 2026, that is yesterday, and is supported by an affidavit of the applicants’ solicitor, Setanta Landers, also sworn yesterday 12 May 2026, and an affidavit of Darragh O’Sullivan, the applicants’ cost accountant, also sworn yesterday 12 May
  2. Separately, Mr O’Sullivan swore another affidavit today, 13 May 2026, in answer to two questions posed by me yesterday and overnight. I will refer to these affidavits further in due course, particularly the two sworn by Mr O’Sullivan.
  3. By way of brief factual background, the applicants are subject to two costs orders from the High Court and the Court of Appeal dated 24 January 2024 and 12 December 2024, respectively, whereby they are responsible for the costs incurred by certain named defendants who are notice parties to the within judicial review Page 2 of 25 application. A bill of costs was first presented on behalf of the notice parties on 16 September 2025, under cover of letter that indicated that the bill of costs would be lodged for adjudication in 21 days. A notice of application for adjudication was lodged on 03 October 2025, and that was returnable for 21 and 22 January
  4. The matter was then adjourned

a call over in January to 25 and 26 of February 2026, and it was further adjourned

a call over in February to 24 and 25 March 2026.

the March 2026 call over, it was indicated on behalf of the applicants that the matter was not ready for hearing, nor was the bill of costs in compliance with O.99, and the Chief Legal Costs Adjudicator gave leave to the applicants to issue a Form 9, returnable before him. This was the first Form 9 already referred to by me, dated 20 March 2026, and it set out the background to the costs issues and to the claimed non-compliance with O.99, and the materials or documentation then outstanding.

  1. When the matter came before the Chief Legal Costs Adjudicator on 24 March 2026, the Chief Legal Costs Adjudicator noted that the costs accountant for the notice parties, being Mr Fitzpatrick, accepted that a file inspection had yet to take place, and that the matter could not proceed on 24 March, and it was listed for 14 and 15 May, that is tomorrow and the day after. The Chief Legal Costs Adjudicator also granted liberty to the parties to apply if any issues arose between the 24 March 2026 and the hearing date tomorrow. But it does not appear from the transcript that I had available to me that any detailed or specific consideration was given by the Chief Legal Costs Adjudicator to the actual contents of the Form 9 on 24 March
  2. The matter then came back before the Chief Legal Costs Adjudicator on 23 April 2026, on a for mention date, where Mr Fitzpatrick indicated that, and I quote, “we are all in good shape for the hearing that’s scheduled on 6th of May.” And Mr O’Sullivan indicated that, “if anything else occurs, then I will bring it to your

tention in advance.” Thereafter, the applicants lodged another Form 9 dated 06 May 2026, in advance of the directions hearing on 07 May 2026, with which the notice parties took issue given the late notification. That Form 9 again set out difficulties including a lack of invoices, lack of supporting documentation and contemporaneous time records, reconciliation issues, lack of information regarding Page 3 of 25 VAT treatment, and it stated that the applicants were not “in a position to properly engage with or proceed to adjudication on a fair and informed basis”. On 07 May

the directions hearing, having heard Mr Fitzpatrick and Mr O’Sullivan, the Chief Legal Costs Adjudicator indicated that he was satisfied that the matter could proceed, and that if there were any issues with the invoices they could be dealt with as part of the determination of costs in the ordinary way. He also stated that VAT was VAT and that it was either chargeable or not chargeable in the ordinary way, and that he was not directed, or not required should I say, to direct proofs or make any determinations in advance of the adjudication hearing on 14 May. It has to be noted that whilst I have had sight of a transcript for the hearings on 24 March 2026 and 23 April 2026, I did not have sight of a transcript for 07 May 2026, and in that regard an

tendance note taken by Mr Landers was exhibited to his affidavit. The affidavit of Mr Landers sets out the above chronology and other matters, and I do not think it pertinent or necessary to refer to that affidavit any further

this juncture. 7. The adjudication of costs is provided for

Part 10

of the Act, by way of O.99 of the RSC and by way of the guidelines already referred to. In brief, s.142 of the Act provides for the preparation of the guidelines; and s.154 to 157 of the Act deal with adjudication of legal costs, insofar as this particular decision is concerned. S.151

(1)directs that a bill of costs be provided to the paying party, who are the applicants in this case, in a manner consistent with, inter alia, the Act, and the RSC. 8. S.154
(2)and s.154
(3), provide, and I am paraphrasing here, that an application may be made for adjudication following

tempts to agree to the bill of costs. S.154

(7)then provides that an application for adjudication may be made, so long as the bill of costs is in a form and manner consistent with, inter alia, the Act. S.154
(10)provides for Rules of Court making provision for, inter alia, the furnishing of documents, records and vouchers to the Chief Legal Costs Adjudicator and to the other parties to the adjudication, and the steps that constitute an

tempt to agree a bill of costs. 9. S.155 refers to Schedule 1 of the Act, relating to the principles relating to legal costs, and that they shall apply to an adjudication. S.155

(4)provides that the Legal Page 4 of 25 Costs Adjudicator shall as respects a matter or item the subject of the application, verify that the matter or item represents the work actually done, determine whether or not it was appropriate that a charge be made for the work or disbursement concerned, determine a fair and reasonable charge for that work or disbursement, and determine whether the costs relating to the matter or item were reasonably incurred. 10. S.155
(5)then goes on to provide that the Legal Costs Adjudicator shall, insofar as reasonably practicable ascertain the nature, extent and value of the work, who carried out the work, and the time taken to carry out that work. S.156 provides for the powers of the adjudicator. S.157 covers the determination of applications, and of particular note is s.157
(4), which provides that a Legal Costs Adjudicator shall, if he or she determines that it is fair and reasonable to charge an amount in respect of an item but that the amount of the charge in respect of the item is not fair or reasonable, determine a different amount to be charged in respect of that item. S.157
(7)provides that if a Legal Costs Adjudicator is of the opinion that a party to the application has neglected or refused to provide documents and that the refusal or neglect would likely be prejudicial to the interests of one or more of the other parties, the Legal Costs Adjudicator shall, in order to minimise the prejudice to those interests, (
  1. a)determine the application to the extent possible in the circumstances, and (
  2. b)determine that only a nominal amount is to be payable to the party who has neglected or refused to provide the required documentation. The determination of the Legal Costs Adjudicator may be subject to a review or consideration by the Legal Costs Adjudicator in accordance with s.160 of the Act, and a review by the High Court, pursuant to the provisions of s.161 of the Act. 11. Part 4 of O.99 of the RSC deals with the adjudication of costs and O.99, r.19 provides that the Legal Costs Adjudicators in the exercise of their powers and performance of their functions, shall have regard to any guidelines published in accordance with s.142 of the Act. O.99, r.21 provides that a Legal Costs Adjudicator may, for the purpose of adjudicating a bill of costs, in addition to the powers exercisable under s.156 of the Act, direct the production of documents, records and vouchers to him or to other parties to the adjudication, require any party to be represented by a separate solicitor (that clearly does not apply here), and, Page 5 of 25 generally direct any party to the adjudication to do such acts as he considers necessary. O.99, r.23
(3)provides that subject to r.26, every notice of application for a party and party adjudication shall be accompanied by (
  1. i)the bill of costs in the form prescribed by these Rules (
  2. ii)vouchers, invoices and/or receipts in respect of any disbursement which has not been agreed, (iii) any other records on which the applicant relies in support of the costs claimed, separately indexed and paginated, and (
  3. iv)where the applicant relies on time records in support of the costs claimed, those time records separately indexed and paginated, showing each legal practitioner or other person concerned, the hourly rate(
  4. s)applicable, the date(
  5. s)on which the relevant work was undertaken and the actual hours or portion of hours expended thereon, a total of the hours, or portion of hours expended thereon, and where any such time is estimated, a statement that such time has been estimated. It then goes on to say that the notice should also be accompanied a true copy of the order of the Court, award of the arbitrator or other order or instrument by which the costs have been awarded or allowed, and in the case of a party and party adjudication applied for by the person subject of the order to pay the costs, a certificate that the person has complied with s.154
(2)of the Act. 12. O.99, r.24
(1)provides that on the initial return date of the application for adjudication, or on any date to which that application is adjourned, the Legal Costs Adjudicator may, if he does not proceed to adjudicate the matters or items concerned in the bill of costs (
  1. i)give directions as to the service of notice of the adjudication on any other person, (
  2. ii)give such further directions, if any, as he considers necessary to the furnishing of further documents, records and vouchers to the Chief Legal Costs Adjudicator or to other parties to the adjudication, (iii) give directions as to the delivery and filing of written submissions (that does not apply here), and (
  3. iv)give such further directions in exercise of the powers available under the Act and O.99, as he considers convenient for the determination of the adjudication, in a manner which is just, expeditious and likely to minimise the cost of the adjudication. 13. O.99, r.26
(1)provides that every bill of costs lodged for adjudication shall be indorsed with the name and registered place of business of any legal practitioner by or for whom it is so lodged, and of relevance to this case ; where VAT is claimed Page 6 of 25 in a bill of costs, the registered number allocated by the Revenue Commissioners to the person registered for VAT must appear in a prominent place in every bill of costs, account or voucher as appropriate, on which VAT is claimed or chargeable. 14. O.99, r.26
(7)provides that where the Legal Costs Adjudicator so directs, a bill of costs may be accepted for adjudication notwithstanding lack of conformity with the prescribed form, provided that the Legal Costs Adjudicator is satisfied that the bill of costs, (i) does not apply to the particular case here, but it does state if a bill of costs furnished by a legal practitioner to a client contains the particulars specified in section s.152
(2)of the Act, and it then goes on to state

, (ii) the Legal Costs Adjudicator must be satisfied that the bill of costs is in the Legal Costs Adjudicator’s opinion sufficient when read together with the documents served and filed together with that bill, to enable the paying party to assess and dispute or oppose the work undertaken, and disbursements incurred, in respect of which the charges are claimed and (iii) it is in the Legal Costs Adjudicator’s opinion sufficient when read together with the documents served and filed together with that bill, to enable the Legal Costs Adjudicator to adjudicate the matters and items in dispute in accordance with the Act. 15. O.99, r.27

(8)provides that where a bill of costs which does not conform to the prescribed form is not sufficient to satisfy the requirements of O.99, r.26
(7), the Legal Costs Adjudicator may (
  1. i)adjourn the adjudication and direct the service and lodgment of a new bill of costs or of an amended bill of costs, (
  2. ii)adjourn the adjudication and direct the service and lodgment of further information or documents in respect of matters or items in the bill of costs, (iii) strike out the application for adjudication without prejudice to the right of the moving party to make a further application. 16. Moving on then to the guidelines prepared under s.142 of the Act. The guidelines refer to both the Act and O.99 and inter alia the parts thereof as I have already outlined, in addition to dealing with adjudication hearings. Under the heading “Rules of the Superior Courts Costs, Rule 2019”, the procedural rules located in O.99 are outlined. They prescribe the process to be followed, the documents to accompany an application, and the forms to be used. It sets out that in applying for Page 7 of 25 adjudication, in addition to the notice of adjudication, the application should be accompanied by the bill of costs in the form prescribed by the Rules of Court, vouchers, invoices and receipts in respect of payments and disbursements and where time is estimated a statement that the time has been estimated. 17. Under the heading “Directions”, it is stated that O.99, r.24
(1)provides that on the initial return date of the application for adjudication or on any date to which that adjudication is adjourned, the Legal Costs Adjudicator may, if he or she does not proceed to adjudicate the matters or items concerned in the bill of costs, give further directions, if any, as he considers necessary to the furnishing of further documents, records and vouchers to the Chief Legal Costs Adjudicator, or to other parties to the adjudication. The Legal Costs Adjudicator may also give such further directions in exercise of the powers available under the Act and O.99, as he or she considers convenient for the determination of the adjudication in a manner which is just, expeditious and likely to minimise the costs of the adjudication. And it is noted under this heading that the general powers of the Legal Costs Adjudicator are located within s.156 of the Act.
  1. Under the heading “Notice of the hearing and some general requirements”, a number of procedural requirements are outlined, most importantly, that the registration number for any persons claiming VAT must be shown where it is claimed. It goes on to state that every bill of costs lodged for adjudication shall be endorsed with the name and registered place of business of any legal practitioner by or for whom it is so lodged. Where VAT is claimed in the bill of costs, the registered number allocated by the Revenue Commissioners to the person registered for the VAT, must appear in a prominent place in every bill of costs, account or voucher as appropriate, on which VAT is claimed or charged.
  2. Under the heading “Form of Bill of Costs”, the provisions in O.99, r.26
(7)and O.99, r.27
(8)are set out. Under the heading “Proof of Work Undertaken” it is stated that apart from the bill of costs and notices, it is also the case that proof of actual work undertaken is required to support the charge being made, whether by a solicitor or barrister or expert or other witnesses, and this will usually require documentary proof. Page 8 of 25 20. Under the heading “Procedures for Adjudication”, it is stated that as a matter of fair procedures, any document being relied on must be made available to the other side and to the adjudicator, in advance of the hearing. Chapter 3 sets out the procedures to be followed

adjudication hearings, including what is set out

s.156 of the Act, and states that there is an obligation on the Legal Costs Adjudicator to have regard to the matters set out in s.155 of the Act. Further, it sets out Schedule 1 of the Act, which prescribes the principles to be applied when undertaking an adjudication.

  1. Under the heading “Lodgement and Tender in Respect of Costs” the guidelines set out that in accordance with O.57 of the RSC, a party who is subject to an order of the court to pay costs may make a lodgment, or if a qualifying party, a tender in respect of the claim for satisfaction of costs.
  2. The affidavit of Mr O’Sullivan to which I have already referred, and that is the affidavit sworn 12 May 2026, was opened to me almost in full by Mr O’Reilly, senior counsel for the applicants, and where not opened it was primarily dealing with statutory provisions, which Mr O’Reilly opened to me separately. In any event, and I am referring now to that affidavit and quoting from paragraphs of that affidavit and averments made by Mr O’Sullivan, where appropriate.

§4

of that affidavit, Mr O’Sullivan avers that he has a positive and professional working relationship with Mr Fitzpatrick, the legal costs accountant for the notice parties. Mr O’Sullivan then goes on to aver that it is usual practice consistent with the terms of the relevant court orders for legal costs accountants to engage directly with each other with a view to agreeing on costs and, if necessary, to reducing the number of matters, if any, requiring determination, thereby assisting the Legal Costs Adjudicator in the efficient conduct of the adjudication. 23.

§5

, Mr O’Sullivan avers that he is aware of the 2021 guidelines to which I have already referred, and that those guidelines place the engagement between the Legal Costs Adjudicators as a precursor to the issuance of the notice of application for adjudication. He goes on to aver that the guidelines are not merely practice guidance but are matters which the Legal Costs Adjudicator is obliged to have Page 9 of 25 regard under the various provisions I have already referred to.

§6

, he avers that

the time of the issuance of the notice of application for adjudication on 03 October 2025, returnable for 21 and 22 of January 2026, that engagement between respective legal costs accountants had not progressed to the stage where cost issues between the parties had been fully identified or addressed. And he then goes on to aver that, in fact, it was his view that the discussions regarding a joint review of the costs were only

an early stage. 24. He then sets out

§7

the sum of the provisions of O.99, and goes on to note that O.99, r.23 sets out that

the time of the service of the notice of application, all of the preparatory work is required to have been carried out and furnished to the other party by way of scheduling of invoices, timesheets and other documentation so that he and his peers can carry out their role efficiently and effectively. He then goes on to say that he believed that the notices were issued prematurely and were inconsistent with the statutory sequence contemplated by s.154 of the Act. 25.

§8

, he avers that it is for the savings of costs and for the efficiency that he and other legal cost accountants can carry out their roles, that all the relevant claims are supported by invoices, timesheets, VAT information, the particulars of the expert witnesses and their invoices and all other supporting documentation which evidence or support the various claims. This makes efficient use of his time and resources when

tending for inspection, that all the relevant information is laid out so that it will be apparent to him that the claims are properly made, and what claims are unsupported. 26.

§9

he avers that he believes that the provisions of O.99 were not complied with in the service of documents, and I believe that that is a matter to which the applicants are not laying much claim

this stage. Moving on then, §10 was not opened because it refers to O.99, r.23 and I have already referred to that. Then he goes on to deal with

§11

, the fact that his office received a notice of application on the 03 October 2025, and he exhibits that notice of application. 27. He states

§12

that, as is apparent from that communication, the full papers were not served in October 2025, and the relevant notice did not comply with O.99, r.23 Page 10 of 25 with regard to proof of service and the contents required under the rules. Moving on,

§13

he deals with the documents furnished in October 2025, and he sets out for the Court in tabular form the various documents that were received, that were partially received and that were not received. For the purpose of timing today, I do not intend to set out those in detail but suffice it to say that there is almost two pages of a table compiled by Mr O’Sullivan in this regard and, as I say, mentioned or averred to

§13of his affidavit.

28. He avers

§14

of his affidavit that he sent a letter to Mr Fitzpatrick on 13 November 2025, setting out the information requested in advance of an inspection. Those requests were for the terms of engagement of the solicitor, including s.68 and s.150 notices; s.150 notices for counsel; copies of all invoices raised from solicitor to client, including any interim bills, together with any supporting documents and particulars of time records if available; copies of all invoices from each expert, together with a detailed breakdown of the expert’s accounts and given that fees have been charged on a time basis, the details in that regard; and copies of all orders referred to in the bill of costs. And again, that letter is exhibited to Mr O’Sullivan’s affidavit. He then goes on to say that on 06 January 2026, and this is

§16

of his affidavit, he avers that he received a reply to his communication from Mr Fitzpatrick, including time records of O’Flynn Exhams Solicitors, referred to as OFX, and of PricewaterhouseCoopers only, as in, the only time records received were those from OFX solicitors and PwC, and Mr Fitzpatrick was also seeking to agree dates for inspection. And again, that letter is exhibited to Mr O’Sullivan’s affidavit. Mr O’Sullivan then goes on to deal with

tending

the various call overs, and I have alluded to those already in this decision. 29.

§19

then, Mr O’Sullivan avers to the fact that in the week preceding the hearing dates there was a call over on Thursday 19 March, and that matter was

tended to by junior counsel Mr Kieran Falvey for the applicants and Mr Setanta Landers, the applicants’ solicitor. Mr O’Sullivan was also in

tendance and during which he avers that submissions were made to the Legal Costs Adjudicator by Mr Falvey that there were deficiencies in the information and documentation provided to Mr O’Sullivan to date, and that it would be necessary to adjourn/vacate the hearing dates, in default of which it would be necessary to bring an application to the High Page 11 of 25 Court seeking a stay pending the issuing of High Court proceedings, pending provision of the outstanding information and documentation. Mr O’Sullivan, continues to aver that the application of counsel for the applicants – or plaintiffs, in that case, the applicants now – was that the matter was not ready for hearing or in compliance with O.99 of the RSC. On that occasion, the Legal Costs Adjudicator indicated that the appropriate course of action would be for the applicants to file a Form 9, and indicated that if this was to be done, it should be filed by the following day. The Chief Legal Costs Adjudicator gave the applicants leave to do so, returnable before him. The Chief Legal Costs Adjudicator, also averred to by Mr O’Sullivan, noted that any applications regarding non-compliance with the rules should be made to him in the first instance. 30. Mr O’Sullivan then,

§20

of his affidavit, explains what a Form 9 is, and given that I have not explained that to date I think it pertinent to record that it is averred

§20

, that a Form 9 is the form created by the Legal Costs Adjudication Office, to make an application to the office for a stay or other directions. A Form 9 was issued on the 20 March, that is within the one-day period allowed by the Chief Legal Costs Adjudicator, and that is exhibited in Mr Lander’s affidavit, and I have had sight of that. I do not propose to deal with that Form 9 in any greater detail

the moment. Mr O’Sullivan, then,

§21

of his affidavit, avers that the matter came before the Chief Legal Costs Adjudicator on Tuesday, 24 March, and that he

tended on that date. And he refers to the fact that an

tendance note is set out in the affidavit of Mr Landers. Now, that

tendance note is actually a transcript of the hearing. 31.

§22

of Mr O’Sullivan’s affidavit, he avers that the Chief Legal Costs Adjudicator delivered his decision on page 28 of 40 as set out

the transcript, and that the Chief Legal Costs Adjudicator expressly flagged that and I quote “I operate on foot of the court orders, of a High Court order, ordering me to adjudicate costs and I have a Court of Appeal order ordering me to adjudicate costs. I am not entitled to look behind those orders and, more importantly, I cannot grant a stay on those orders not that it was framed in that way. It was more that it would be more efficient if matters were adjourned and all matters could be dealt with Page 12 of 25 together that is a matter for the court. There is no stay on the orders so I will be proceeding with the adjudications.” 32. Now, I will insert here that that application for a stay is a different application than the application for a stay before me today, and the application for a stay referred to in the transcript of the determination on 24 March is not a stay or an application that the applicants are now progressing before me.

§23

of Mr O’Sullivan’s affidavit he goes on to aver that counsel for the applicants argued on 24 March that there was, again, material non-compliance with O.99 of the RSC in terms of outstanding materials, and the full Form 9 was opened to the Chief Legal Costs Adjudicator. Mr O’Sullivan avers that counsel may refer to the full transcript of the hearing in due course, but he goes on to aver then, that it is apparent the Chief Legal Costs Adjudicator did not seriously or in any substantive way address the documentary deficiencies which existed

that time, even

that stage, nor were the documentary deficiencies properly explained by the representatives for the notice parties. When matters concluded on 24 March 2026, the Chief Legal Costs Adjudicator did not make any directions as regards the documentary deficiencies.

§24

there is an averment, but I am going to move on because the applicants before me are not challenging the matter on that basis, and I then move to §25 of Mr O’Sullivan’s affidavit,

which he avers that O.99, r.26

(7)provides that a bill of costs and I quote “may be accepted for adjudication, notwithstanding lack of conformity” where the Legal Costs Adjudicator “so directs”, and on the proviso that the Legal Costs Adjudicator is “satisfied” that the bill of costs in his “opinion” meets the other criteria concerning the sufficiency of the other documentation when read together and the documents filed together with the bill of costs, to enable the paying party to assess and dispute the work undertaken, and to enable the Legal Costs Adjudicator to adjudicate matter, etc. 33.

§26, Mr O’Sullivan then avers that the position is that the rules require strict compliance with the requirement of O.99, r.23

(1)-
(3)to provide specified categories of information and documentation and the Legal Costs Adjudicator must ensure compliance with the requirements of the Act and O.99, r.23
(1)-
(3)as set out above. I should note

this juncture that Mr O’Reilly did accept

hearing on 12 May, that is yesterday, that there were perhaps parts of Mr O’Sullivan’s affidavit Page 13 of 25 that were more by way of legal submission as opposed to factual matters. But given the short period of time between 07 May and 12 May, and also given the very short period of time between the hearing and the proposed adjudication tomorrow, I am prepared, for the purpose of this decision, to accept that there are certain legal submissions in the affidavits. And clearly issue may be taken with those in due course, if that is what the respondent or the notice parties wish to do. 34.

§27

of Mr O’Sullivan’s affidavit, he avers that to the extent that the adjudicator has any discretion to “accept for adjudication” a bill of costs which does not conform with the requirements of the rules, that discretion may be found in O.99, r.26

(7)of the RSC. He then goes on to aver

§28

of his affidavit that, taken

its height, O.99, r.26

(7)could be said to provide the Legal Costs Adjudicator with a discretion, however it is important to note that the exercise of the discretion is conditional upon a direction actually being actually given. In other words, taken

its height, the exercise of the discretion requires that the adjudicator“so directs”.

§29

of his affidavit, Mr O’Sullivan avers that on 24 March 2026, when the difficulties with the conformity were again raised by the applicants before the adjudicator on that occasion, the Legal Costs Adjudicator set the matter down for hearing on 14 and 15 May, without giving any further direction. And he said, and I quote, “I do not like giving formal directions unless they are required so I will not give a direction in it. I will just list it for hearing on the 14th and 15th and if there is any difficulty then you can come back to me in the meantime”. 35.

§30

, Mr O’Sullivan goes on to aver that on that occasion, although the lack of conformity had been specifically raised on a number of occasions by that stage, the Legal Costs Adjudicator did not give any direction that the bill of costs “may be accepted for adjudication, notwithstanding lack of conformity”. Not only that, he gave no direction whatsoever, in fact, stating that he was not giving any direction, even if any discretion were to be argued to have somehow been exercised

that stage, it is clear that no such discretion was exercised in conformity with O.99, r.26

(7)because no direction was made as required and in fact no direction was made

all, as was made clear by the Chief Legal Costs Adjudicator in his express statement to this effect. He goes on then, in §30, to note that the Chief Legal Costs Page 14 of 25 Adjudicator listed the matter for hearing on 14 May 2026, with liberty to apply if any issues arose, and with the matter listed for mention on 23 April 2026. 36.

§32

he notes that he received a letter from Mr Fitzpatrick on 09 April seeking inspection dates, and that an actual inspection of the High Court file was carried out on 15 and 16 April 2026, and the Court of Appeal filed subsequently on 06 May 2026. Obviously, those files being the solicitor’s files dealing with the matters before the High Court and the Court of Appeal.

§33

he then avers that the matter came before the Chief Legal Costs Adjudicator on 23 April 2026, for mention, and that he was in

tendance on that date. And again, he refers to a copy of the

tendance exhibited by Mr Landers, and that again is a transcript. And the Chief Legal Costs Adjudicator indicated that if any issues arose that there was liberty to apply. 37. He then goes on

§34

to note that he wrote to Mr Fitzpatrick by letter on 05 May 2026, and he exhibits that communication, and that communication, for the purpose of time I am not going to deal with each issue, but it sets out that a complete and coherent set of invoices had not been furnished, time records had been sought but not been provided, and Mr Fitzpatrick’s response to Mr O’Sullivan did not address queries raised. It sets out that there remained a clear reconciliation issue, that the position was not limited just to reconciliation issues, there were also other issues as regarding invoices. And, in terms of time records, in circumstances where fees were claimed that any supporting time or narrative records, it was not possible to assess the nature, extent or necessity of the work undertaken. And then it also deals with the lack of clarity as to the correct VAT treatment and liability. Mr O’Sullivan then goes on

§36

to refer to the lack of supporting documentation and lack of specificity, and that in simple terms, with regard to invoices rendered, it was impossible for him to form a cogent and informed professional view that such claims were properly made, or indeed he could not challenge same because without the details of the underlying calculations, he could not formulate a view on whether the calculations were appropriate and in line with best practice and

acceptable charge out rates, or whether the quantum of time incurred was commensurate with the quantum of the claim raised. In other words, were all claims properly made and in the right amount. Then he goes on to deal with the inspection on the Court Page 15 of 25 of Appeal file on 06 May, and then

§38

he avers that given the breadth of unresolved issues, it was appropriate to file a further Form 9 on 06 May, seeking the guidance of the Chief Legal Costs Adjudicator in addressing the outstanding issues, and that that Form 9 again raised the issues with respect to documentary deficiencies, and again sought directions to include that the hearing be stayed pending the provision of the outstanding information and documentation in order to secure a fair hearing. And again, that second Form 9, dated 06 May, is exhibited in the affidavit of Mr Landers. 38. He then sets out in §39, that the notice parties objected to the filing of the Form 9, given the very short period between the filing of the Form 9 and the matter coming before the Chief Legal Costs Adjudicator the following day. Indeed, there may be an issue as to the fact that it was served in an even shorter time frame. But in any event, Mr O’Sullivan then avers

§40

of his affidavit that the matter appeared before the Chief Legal Costs Adjudicator on Thursday 07 May, and he refers to an

tendance prepared by Mr Landers, solicitor, and that he believes that it is an entirely accurate record of what occurred before the Chief Legal Costs Adjudicator on that date, and it is an accurate record of the decision of the Chief Legal Costs Adjudicator on that date. As I have mentioned already, there is no transcript available for that. The memorandum prepared by Mr Landers is, I suppose, the best evidence before me

the moment. 39. Mr O’Sullivan then goes on to note

§41

of his affidavit that the Chief Legal Costs Adjudicator had indicated that he had read the Form 9 but that, notwithstanding the issues that were identified as outstanding, he intended to go on with the hearing on 14 and 15 May for adjudication. Mr O’Sullivan avers

§42

of his affidavit, that on 07 May, the Chief Legal Costs Adjudicator again did not exercise any discretion in any express manner, nor did he give any direction to the effect that the bill of costs “may be accepted for adjudication notwithstanding lack of conformity”. And the adjudicator actually stated, “I am not required to direct any proofs or make any determinations in advance of the adjudication hearing itself and on that basis I will set the matter down for hearing on 14 and 15 May

10am”. Page 16 of 25 40. Mr O’Sullivan then avers that it is again apparent that even if any discretion were to be argued to have been exercised, for example implicitly

that stage, it is clear that no such discretion was exercised in conformity with O.99, r.26

(7)because no direction was made as required. And again, in fact, no direction was made

all, as was made clear by the Chief Legal Costs Adjudicator in his express statement to that effect.

  1. Mr O’Sullivan then sets out in §43 the documentary deficiencies that remained and they include the following; despite requests, a complete and coherent set of invoices were not furnished in respect of the second firm of solicitors in the proceedings; certain invoices referring to time records were not furnished; reconciliation issues involving O’Flynn Exham’s invoices and time records and apparent duplication of invoices and references within the time records to invoices for which no corresponding documentation had been produced; contemporaneous time records were not furnished in respect of the first firm of solicitors on record, notwithstanding that the terms of engagement were on an hourly basis. He also goes on to aver that this only emerged in a files inspection on 15 and 16 April 2026, that again is the solicitor’s files.
  2. He then avers in §44 that in the Form 9 he made it clear that the paying party, as in the applicants in this case, were not in a position to ascertain the full extent of the notice parties liability to their solicitors, and the Form 9 also raised significant issues involving VAT treatment and liability. The Form 9 complained about documentation being furnished in a piecemeal fashion in close proximity to the adjudication dates, and he also made it clear that the applicants were not in a position to properly engage with or proceed to adjudication on a fair and informed basis. 43.

§45

, he avers that the uncertainty as regards VAT affected not merely his quantum and liability assessment, but also his ability to advise the applicants on considering statutory tender/lodgment options. And that in addition, the missing vouchers may also preclude the confirmation of disbursements.

§46

, he observes that his impression from the hearings and from the approach adopted by the Chief Legal Costs Adjudicator was that he was minded to allow the adjudication Page 17 of 25 process to continue notwithstanding the outstanding documentation and issues raised, with those matters to be dealt with more fully

the substantive hearing of the bill of costs. In other words,

the adjudication tomorrow. He goes on to aver that one could understand that this might be done with the motivation to establish efficiency but he states that this approach actually creates more inefficiency and more work and more uncertainty. He goes on to aver that the costs hearing is presently listed for hearing on Thursday 14 and Friday 15 May, and that he did not yet have a full understanding of either the High Court or Court of Appeal file, that communication was issuing to him piecemeal as late as Friday 08 May, which was less than a week prior to the hearing. He then avers that his understanding of the guidelines to which I have already referred, is that they provide a regime where notices are required to be complete and all supporting documentation is to be provided for

the time the matter is set down for hearing, after the parties have had an opportunity to engage with the papers, and after the parties have had a reasonable opportunity to be heard. He avers that he is aware that there are provisions to allow the Legal Costs Adjudicator to make directions and to accept notices that might not be in strict compliance with the orders and the guidelines, but the facts of this particular case is that no meaningful engagement took place prior to the service of the notices and, in Mr O’Sullivan’s view, no meaningful consideration of the outstanding information set out in the Form 9s took place. He then observes that the breadth of the omissions are not minor stray invoices, but there are significant and material gaps in the entire bundle, that he had already identified in the Form

  1. He had raised concerns around duplication of invoices, lack of VAT information, and the VAT status of entities, and the lack of timesheets to support invoices. He avers that these were not minor or technical breaches, but that they were, in his view, fundamental and important issues that go to procedural fairness and the ability of his office to carry out the services that they had been engaged to do. He then avers that there was no adequate explanation given as to how the matter could fairly proceed despite the identified non-compliance.
  2. I have referred to Mr O’Sullivan’s affidavit in large part because it is his evidence that is before me as an expert in this area that he cannot, in the interests of fairness, deal with the adjudication tomorrow, given, as I am calling it, the information deficiencies that exist

the moment. When hearing the application yesterday, I Page 18 of 25 raised a question and that was dealing with the “normal”, if I can put it that way, time interval between submitting a bill of costs and making an application for adjudication, and Mr O’Sullivan averred to that in an affidavit sworn by him today, that is 13 May. He avers

§6

to the question that I have just referred to that in respect of the Court’s question as to whether the notice of adjudication was precipitous, the usual process is that the bill of costs would be served, and a period of time would be given to allow for agreement in advance of serving the notice of adjudication. He goes on to aver that there are no set timeframes for this other than a notice of adjudication cannot be served

the same time as a bill of costs.

  1. I then, however, had posed a second question for Mr O’Sullivan, and that second question related in part to §13 of Mr O’Sullivan’s initial affidavit, sworn 12 May
  2. Whereas I have already noted he set out in tabular format the documentation that had neither been received or was only partially received, and I was curious overnight as to the likely volume of outstanding documentation. And I did say to Mr O’Sullivan that whilst it might be akin to asking him to prove a negative, or asking the applicants to prove a negative, I wondered if any “guesstimate” could be put on the volume of the documentation awaited. I also indicated to Mr O’Sullivan that I might be asking him to look into a void, but I thought that there was a world of a difference between, for example, 50 missing pages and 500 missing pages. My concern or my query was that if this documentation were produced

the commencement of the adjudication tomorrow, could Mr O’Sullivan deal with it overnight, which might have been possible if the volume of material were small, or was it likely to require a lengthier consideration by Mr O’Sullivan, and that clearly was more likely if the volume of documentation were large. Mr O’Sullivan did swear to that in his affidavit sworn today, and

§3

he avers that it was on my request to query the extent of the information that is outstanding and how quickly it could be dealt with, that I indicated that I appreciated that, that I might be asking him to prove a negative, but I was looking for a guesstimate on the volume of documentation awaited.

§4

of his affidavit, he averred that it was difficult

present to provide any reliable estimate by reference solely to page numbers. The issue was less whether the outstanding material amounts to 50 or 500 pages, but more whether the documentation ultimately produced was capable of meaningful review, reconciliation and Page 19 of 25 verification against the file and the papers. He also averred that further documentation and correspondence, including time records, were furnished late last Friday, following the inspection process that had already been undertaken. He then averred that concerns identified

§13

of his affidavit, to which I have referred, and the Form 9 application, principally related to time records, invoices and supporting documentation across multiple firms and entities, together with the need to reconcile same against the bills and liability material furnished. He averred that given that the bill advanced is a claim of €3.2 million approximately, spanning multiple firms and entities, the review required was not simply one of volume but of proper reconciliation and verification. 46.

§5

, he averred that based on his experience in reviewing bills of this nature, the outstanding documentation in issue appeared to extend to substantial time records, invoices, accounting material and VAT-related documentation, requiring detailed consideration and reconciliation. In those circumstances, he averred that it was difficult to see how such material could realistically be reviewed in any meaningful way, if only produced

the commencement of the adjudication or shortly before the adjudication. He also averred that, for the assistance of the Court, as set out in §46 of his affidavit that he had received further information on Friday last, and had spent significant time reviewing same, including today, 13 May, in preparing as best as he could for the hearing scheduled tomorrow and Friday. But the delivery of outstanding information on a piecemeal basis, given that the bill has advanced a claim of approximately €3.2 million spanning multiple firms and entities, did not allow for proper reconciliation and verification and, as he understood it, was neither in conformity with the rules nor the guidelines. And that is the extent of the expert evidence available before me. 47. Moving on then to the substantive part of my decision, and I have taken a significant period of time in outlining the factual matters and the expert evidence from Mr O’Sullivan, because I am mindful of the orders that I am about to make. They are in essence in favour of the applicants, but I am very mindful that they are orders being made

very much the last minute and again, I take no issue with the applicants in this regard, given that the matter was last before the Chief Legal Costs Adjudicator only last Thursday. So first and foremost, and as regards the Page 20 of 25 application for leave to issue judicial review proceedings, the applicants have to satisfy me that they have an arguable ground or grounds. I am satisfied that the applicants have such arguable grounds, in circumstances where firstly, the Chief Legal Costs Adjudicator does not appear to have made any determination on the two Form 9s and whether or not the applicants can properly engage with the adjudication on a fair and informed basis, in circumstances where the bill of costs does not conform with O.99, r.23 of the RSC. Secondly, the Chief Legal Costs Adjudicator does not appear to have made any determination or direction that the bill of costs may be accepted for adjudication, notwithstanding lack of conformity, and that determination or direction could be made pursuant to O.99, r.26

(7). Then thirdly, for the reasons underpinning the lack of determinations as set out above, I am also of the view that there is an arguable ground that the Chief Legal Costs Adjudicator failed to take into account the guidelines published by his office in September 2021, those guidelines being made pursuant to s.142 of the Act. 48. However, that is not the end of the matter. Prior to granting leave to issue judicial review proceedings, I must also be satisfied that the applicants have exhausted alternative remedies. It appears to me that on one level it could be suggested that the applicants are somewhat precipitous in their application, particularly given the provisions of s.160 and s.161 of the Act. And if I am not mistaken, there is also the reference in s.157
(7)permitting that if the Legal Costs Adjudicator is of the opinion that a party to the application has neglected or refused to provide documents, and that the refusal or neglect would be likely to be prejudicial to the interests of one or more of the other parties, the Legal Costs Adjudicator shall, in order to minimise the prejudice to those interests, (
  1. a)determine the application to the extent possible in the circumstances and, (
  2. b)determine that only a nominal amount is to be payable to the party who has neglected or refused to provide the required documentation. It seems to me that s.157
(7)has not been engaged by the Chief Legal Costs Adjudicator to date. And given both Form 9s as presented to the Chief Legal Costs Adjudicator, he has not engaged, it seems to me, to any detailed extent or specific extent with those Form 9s. In the circumstances, I am of the view that although it could be seen as an alternative remedy, I am not of the view that the applicants are precluded from bringing a judicial review application in the circumstances, notwithstanding the provisions of s.157
(7). I think also s.160 and Page 21 of 25 s.161 can be taken to be referable to an adjudication that has taken place on, if I can put it this way, a full facts basis, and where there is not an information deficit, which exists, in this Court’s view,

the moment and based upon the expert evidence of Mr O’Sullivan. It is for this reason and given the information deficits in this case, I am satisfied that the applicants do not have an effective alternative remedy available to them, if the Chief Legal Costs Adjudicator were to proceed to an adjudication on 14 and 15 May, as intimated by him last Thursday, 07 May. 49. In coming to this conclusion, I am mindful of the decision of the Supreme Court, the recent decision of the Supreme Court in LA v. The Chief Appeals Officer [2026] IESC 22, where Donnelly J, in giving judgment for the Court, set out

§105

the following principles in relation to the Court’s discretion to refuse judicial review where an alternative remedy exists. Inter alia, she states that the default position is that a party should pursue a statutory appeal or review rather than initiate judicial review proceedings and that the rationale for this principle was multifaceted, but in effect it is to give effect to the legislative intent in the creation of alternative remedies; that there may be advantages to having an appeal over judicial review, that is, to safeguard judicial resources so that the courts remain available to provide speedy relief in other cases where intervention is required; and the implication for costs and/or for delay for both claimants and for the State and public bodies in applying for judicial review instead of using the alternative appellate machinery. The exercise of discretion to refuse to grant a remedy of judicial review which may otherwise be justified is tightly bounded by legal and constitutional considerations. The High Court’s judicial review power over administrative bodies and courts of limited jurisdiction acts as a safeguard to the rule of law, and the balancing of these important legal and constitutional considerations is central to the exercise of this Court’s discretion. Cases where judicial review will be permitted are exceptions to the general rule, an applicant may not have to exhaust an alternative remedy where it is not adequate, or where there is a particular exigency in the interests of justice which requires judicial review to lie. And in the circumstances of this case and primarily that there would appear to be a significant information deficit, and given the matters referred to by Mr O’Sullivan on affidavit, I am satisfied to exercise my discretion and grant leave to issue judicial review proceedings. Page 22 of 25 50. I then must turn my

tention to the request for a stay, and in so doing, I am mindful of the decision of Clarke J in Okunade v. Minister for Justice [2012] IESC 49; [2012] 3 IR 152, in respect of which I was referred to §31-158 of the most recent edition of Delany and McGrath on Civil Procedure by Mr O’Reilly for the applicants. And again, I think it is important to quote so that the applicants and indeed the respondent understand where I am coming from in terms of granting a stay, and I quote from the most recent edition of Delany and McGrath on Civil Procedure as follows. It is stated therein

§31

-158: “The seminal authority which sets out the test for a grant of a stay in judicial review proceedings is Okunade v. Minister for Justice, Equality and Law Reform. Clarke J stated that when faced with the question as to what is to happen pending a full trial the Court has to balance the competing legitimate interests involved, and that it did not seem to him that the task of balancing those interests was different depending on whether the measure sought to be challenged was one which should be quashed by certiorari or prohibition, or whether an injunction was considered the appropriate means of intervening. In his view, the Court must in all cases act so as to minimise injustice. And he stated as follows: The underlying requirements of justice are not dependent on the form of judicial review order ultimately sought or the form of temporary order applied for. It does not seem to me, therefore, that the criteria to be applied in deciding whether a stay should be excluded under O.84 r.20

(7)(a) are, in principle, be any different to the criteria which are to apply where the court is invited to grant some other form of interim relief under O.84 r.20
(7)(b). Clarke J stated that the criteria that must be met where a stay is sought are largely those derived from the decision of the Supreme Court in Campus Oil Ltd v. Minister for Industry and Energy No. 2, although he acknowledged that there may be distinct features applicable in judicial review proceedings. He added that in such cases, where the risk of injustice may be evenly balanced, it seemed to him that there may be greater scope for the Court to take into account the strength of the case than may apply in the ordinary injunction case. Clarke J summarised the overall test for considering whether to grant a stay or an interlocutory injunction in judicial review proceedings in the following terms: (a) The court should first determine whether the applicant has established an arguable case; if not the application must be refused, but if so then ...” and in this case I am satisfied that the applicant has Page 23 of 25 established an arguable case. And if so “the Court should consider where the greatest risk of injustice would lie", and in taking this consideration into account, Clarke J enumerated four principles. I do not see the need to go into them in any great detail here given that in many respects they rely on public interest issues as such. It is then stated

(c) that “The court should, in those limited cases where it may be relevant, have regard to whether damages are available and would be an adequate remedy and also whether damages could be an adequate remedy arising from an undertaking as to damages", and I will return to that shortly. And then

(d) “In addition, and subject to the issues arising on the judicial review not involving detailed investigation of fact or complex questions of law, the court can place all due weight on the strength or weakness of the applicant’s case.”

  1. As I have already stated, I believe that the applicant has an arguable case in this matter and hence I am, in any event, satisfied to grant leave to issue judicial review proceedings. I think it also relevant to mention in passing the recent Supreme Court decision in the matter of TikTok v. The Data Protection Commissioner [2026] IESC 27, but I am of the view that the judgments of Murray J and Hogan J regarding a stay on administrative decisions do not have a bearing on the particular case before me, since the case before me is not concerned, in my view, with a major regulatory decision. Therefore, in my view, the Okunade principles, as I have already alluded to, apply in the circumstances, and in applying those to the present case and given the matters already referred to, I find that the applicant has an arguable case, the greatest injustice lies in allowing the adjudication to proceed tomorrow, and I am prepared to grant a stay. In coming to this conclusion, I am mindful of the applicant’s undertaking as to damages as outlined to me by Mr O’Reilly SC, and that undertaking is as follows; the applicants give an undertaking that Courts Act interest will apply on the currently unascertained sum to be ultimately adjudicated by the Legal Costs Adjudicator in respect of the High Court costs and Court of Appeal costs (the subject matter of this application) from the date of issuing the statement of grounds on 12 May 2026 to the date of the conclusion of the within judicial review proceedings. This undertaking will only be of legal effect, if I can put it that way, if the applicants are unsuccessful in the substantive judicial review proceedings, and if they are so unsuccessful, they will pay the Courts Act interest. Page 24 of 25
  2. In the circumstances, I am prepared to make the following orders. I am satisfied to grant the applicants leave to issue judicial review proceedings on the grounds as set out

ground 1(ii) of the ex parte docket, (and not ground 1(i), noting while that counsel for the applicant indicated

hearing that leave was solely being sought on ground 1(ii), no concessions were being made as to what occurred

1(i)); ground 1(ii); ground 1(iv); ground 1(v); ground 1(vi); ground 1(vii); ground 1(viii); ground 1(ix). I am not granting leave on ground 1(x). Ground 1(xi) is damages, and I suppose that can flow in due course, whether or not the ultimate court hearing the application is prepared to award them or not. And I will reserve the question of costs both in relation to the ex parte leave application and the stay application.

  1. As regards directions as to service. First of all, I think the applicants’ solicitor should notify the Office of the Chief Legal Costs Adjudicator immediately following this hearing as to the fact that an application was made yesterday, it was continued into this morning, that application sought leave to issue judicial review proceedings, I have granted leave to issue judicial review proceedings, and it should set out the paragraphs of the ex parte docket upon which I have granted that leave. It should also indicate that I have granted a stay on the adjudication proceeding tomorrow, and that a perfected order will follow in short course as soon as the Registrar is in a position to draw up that order, whether that is this evening, and I am very mindful of time, or tomorrow morning. But I am very conscious that the Office of the Chief Legal Costs Adjudicator and the notice parties need to be informed forthwith of the making of the orders, and I think that should be both by way of telephone, if possible, and by way primarily of email.
  2. The notice of motion should issue within seven days of today’s date and all papers, including the motion, should be served on the respondent and the notice parties within the same seven-day period, and the motion should be returnable to 30 June
  3. Page 25 of 25

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