“…und in, for example, Mitchell v James [2002] EWCA Civ 997, [2004] 1 WLR 158, C v D [2011] EWCA Civ 646, [2012] 1 WLR 1962, Shaw v Merthyr Tydfil County Borough [2014] EWCA Civ 1678, [2015] PIQR P8 and James v James [2018] EWHC 242 (Ch), [2018] 1 Costs LR 175. In Mitchell v James (where an offer had provided for the parties to bear their o…”
“…s court held that the offer was therefore not in accordance with Part 36. And in both C v D & Anr [2011] EWCA Civ 646, and Shaw v Merthyr Tydfil County Borough [2014] EWCA Civ 1678, this court held that offers that sought to amend the time for acceptance stipulated by r.36.5 were also outside Part 36.…”