Falcon Trident Shipping Ltd v Levant Shipping Ltd [2021] EWHC 2204 (Comm) – 4 August 2021 (Clare Ambrose sitting as a Deputy Judge of the High Court)

London jurisdiction having been agreed by the two owners following a collision in India, liability was admitted and quantum settled by an accepted pre-action ‘Part 36’ offer, appending a more detailed Settlement Agreement.  In addition to its London lawyers’ and Club costs (comprised in the ‘Part 36’), the Claimant (in costs proceedings) sought additional fees of Indian agents, lawyers and P&I Correspondents and those of its H&M insurers’ Italian lawyers.  The Court found that whilst these items might have been open for recovery under the ‘Part 36’ terms, they were in fact covered by the more detailed Settlement Agreement, which superseded the ‘Part 36’ terms.