1069 - 1615

Expert witnesses - not always reasonable

Ross v PGS Productions A.S [2009] CSOH 45

The assessment of expenses in Scottish cases is always of interest. The starting point is that a party awarded expenses will calculate them using the published table for judicial expenses, where there is a fixed fee for each step in the litigation, rather than by reference to the amount of time spent on the case. This case highlights the vexed questions of when a party can claim further expenses for an expert and when the solicitor is entitled to an additional fee.

The action concerned an accident on an off-shore installation in which the pursuer suffered significant injuries. He was employed as a deck foreman with the defenders and he, along with his deck crew, was instructed to repair a damaged mooring line. Tension was required to carry out the repair and this was initially provided by a chain block. The block failed but was replaced with a capstain winch. The winch increased the tension on the repair and as a result a hook spun away, striking and injuring the pursuer's left hand.

There was no dispute between the parties as to how the accident happened. The defenders accepted that the capstain should not have been used for the job the pursuer was carrying out. The point in dispute was therefore whether the use of the capstain by the pursuer was authorised, or at least tolerated, by the defenders.

The case subsequently settled and came before Lord Malcolm on the issue of whether two expert engineers, instructed by the pursuer, should be certified as skilled witnesses. Certification would allow the pursuer to recover the costs of the engineers' investigations and reports. The defenders opposed the certification. The test set out in the Rules of Court states that the court must be satisfied that it was reasonable to employ an expert witness to make investigations or to report on the case for any purpose.

In opposing, the defenders submitted that it was not reasonable to have instructed one expert engineer, never mind two. It was clear that the issues in dispute were very narrow indeed. In fact, the only issue was the question of authorisation to use a capstain. As this was a matter of fact, which could only be resolved by lay witness evidence, there was nothing on which an expert could comment. Instructing two expert witnesses was simply excessive.

In response, the pursuer submitted that this had been a very complicated case involving both senior and junior counsel. Two consultations had been held with one of the experts as it was necessary to understand precisely the mechanics of the incident and how it had occurred. However, the pursuer could not explain why the reports were so wide ranging, covering irrelevant issues, and could not produce the letters of instruction.

In making his decision, Lord Malcolm had no hesitation in agreeing with all of the submissions for the defenders. He was satisfied that it was 'tolerably clear' from the pleadings that the issue in dispute was a matter of fact, and not one requiring expert opinion. Neither of the reports were required to assist in the resolution of the case. The engineers had acted more like claims consultants than independent experts giving advice and assistance to the court.

The pursuer had also sought an additional fee for the solicitors based on the complexity of the case. Lord Malcolm also refused this motion and noted there was a lack of information upon which he could reach a decision. He did however remit the matter to the Auditor of Court for determination. It is the Auditor's task to fix the level of expenses where parties cannot reach agreement.

This case highlights the importance of giving careful thought to the selection and instruction of experts, but more importantly for defenders, to question the certification of the pursuer's witnesses. Experts are expensive. One must therefore apply this test: Was it reasonable to instruct an expert at all? If so, has the expert offered an opinion or simply recounted the facts of the case?

Expenses for an expert are far more wide-ranging than just the cost of a report. Fees for the solicitor revising the report and for the expert attending consultations, together with cancellation fees for trial, all add considerably to a pursuer's account. It is therefore in insurers' best interests for expenses to be challenged wherever possible.

Contributed by Jennifer Gammell

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