1069 - 1694

Calculation of damages and deductible elements in serious injury cases

Crofton v NHSLA - Court of Appeal, 8 February 2007

This case concerned a 26 year old man (at date of trial) who had suffered a serious brain injury when he was a few days old leaving him with the mental age of a young child and requiring 24 hour care.

The Court of Appeal decided that 'direct payments' (payments that the Council would or might make to the claimant towards his care costs) may be taken into account in the assessment of damages. However, it cannot be assumed that direct payments will always be made. The Court of Appeal makes it clear that it very much depends upon the circumstances. The view is taken that there may be cases where the possibility for a claimant receiving direct payments is so uncertain that they should be disregarded altogether in the assessment of damages. It will depend on the facts of the particular case. It would therefore seem prudent for insurers to obtain appropriate expert reports to allow offers to be set at the correct level. If a court finds a claimant will receive direct payments for at least a certain period of time and possibly for much longer this finding must be taken into account in the assessment.

Iqbal v Whipps Cross University Hospital NHS Trust - Queen's Bench Division, 8 December 2006

This deals with a number of issues. It suggests the model of the single resident carer is redundant due to the application of the Working Time Regulations. A claimant may not need physical or direct attention for every hour of the day but may need a carer to be on call. It appears that the whole of the hours when a worker is required to be in the premises and be on call count as working time for the purposes of the Working Time Regulations. This means that the employed carer is entitled to periods of consecutive hours of rest free from being on call, with the consequence outlined above for the model of a single resident carer. Iqbal also addresses how an award of damages should deal with the employers' add on costs. Iqbal adopted the reasoning in A v B Hospitals NHS Trust 2006 EWHC 1178. There it was argued by the claimant that the on costs associated with the care regime should be individual costings on the basis of a 58 week year. For the defendant it was argued that the care costs should be calculated by reference to a 52 week year but should be uplifted by 27% to reflect the costs of national insurance etc. In A v B it was said that neither system is particularly precise but in the nature of things complete precision will not be possible and on balance the claimant's approach was followed. The reasoning being it was said to be more likely to reflect the actual costs which will be incurred. That said, Iqbal does not give rise to a legal rule on the treatment of 'on costs'. The court simply preferred the view of one of the experts as to the best way of doing this. It would be open to another court to approach matters differently.

Dealing with Crofton first there was support for the defendants in instances where there is a possibility of double recovery by a claimant for direct payment. Insurers need to look at ways in which they can maximise this support. Offers may have been made to pursuers which do not reflect the existing local authority funding arrangements. This must not be lost sight of and perhaps reconsideration or even withdrawal of such offers may be the most appropriate course. Separately the seeking of advice on the issue of Section 29 funding should also be considered.

In Iqbal the issue of single resident carers was considered to be in breach of the European Working Time Directive. However, some of the added extra costs like recruitment and ERNIC costs were unrecoverable.

Contributed by Douglas Brodie

Subscribe to our news feeds

Keep up-to-date with all of our publications, legal updates, firm news and events.

Firm NewsLegal UpdatesSMIBEvents