Updated: 25/09/2025
Reading time: 5–7 mins

Quick definition (featured-snippet friendly):

Mazur & Stuart v Charles Russell Speechlys [2025] EWHC 2341 (KB) confirms that unqualified staff may assist a solicitor but cannot “conduct litigation”, even under supervision. The High Court also set aside a £10,653 costs order, making no order as to costs on appeal.
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• Free trial: We’ll draft & negotiate one bill to settlement at no charge.
• After that: £500* fixed fee per file (all-in). *HDR & MOD NIHL
• SLA: 5 working days. Costs Lawyer–led. UK-wide, paperless.
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The case in 60 seconds (for busy partners)

• Unqualified employees cannot conduct litigation. They can support, but conduct must clearly sit with an authorised, qualified person.
• The court endorsed a “question of fact and degree” approach—look at who takes decisions, approves pleadings, and assumes responsibility for formal steps.
• A first-instance order requiring the defendants to pay £10,653 when the stay was lifted was set aside on appeal → no order as to costs.
• Neutral citation: [2025] EWHC 2341 (KB).
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Why this matters for your costs recovery

The judgment arms paying parties with fresh Points of Dispute around entitlement and recoverability where files suggest paralegal-led conduct. Expect scrutiny of:
• Signatures/approvals on claim forms, PoC and applications.
• Time entries implying strategic decisions by unqualified staff.
• Delay/stay-related time (reasonableness & proportionality if entitlement was in doubt).
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How DMD Costs protects your bills (and maximises net recovery)

We draft to the judgment. Our workflow and narrative style reflect the fact-and-degree test—evidencing solicitor control where it existed and isolating tasks that are purely mechanical.
• Pre-bill audit (free on the first file): sign-offs, role clarity, delegation vs conduct.
• Bill drafting that anticipates PoDs: explicit supervisor approval lines; admin time ring-fenced.
• Strategic Replies: we neutralise entitlement points with file evidence and concede low-yield items tactically to protect the big ticket.
• DA-ready structure: clear chronology, work-type taxonomy, and proportionality signposting.
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Compliance quick-wins (copy/paste for your team meeting)

• Signature discipline: formal documents signed/approved by a qualified person.
• Time-entry wording: “Drafted by [Paralegal]; approved by [Solicitor]; [Solicitor] responsible for conduct.”
• Role separation: paralegals = mechanical tasks (bundles, searches, service)—not “conduct”.
• Pre-issue entitlement check: named conducting fee-earner; PC in force.
• Stay prevention: 10-minute partner review before issue.
• Vendor oversight: if using a recovery partner, ensure a solicitor truly conducts the case.
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Our pricing (simple, fixed, predictable)

• Free first bill to settlement (trial).
• £500 all-in per file thereafter (drafting + negotiations + settlement paperwork).
• HDR & MOD NIHL specialists. Every penny recovered.
CTA: Send your first file → info@dmdcosts.co.uk
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FAQs

1. 
   Can paralegals “conduct litigation” under supervision?
   No. They may assist, but conduct remains a reserved activity for an authorised person.
   
2. Does a firm’s authorisation automatically cover employees?
   No. Authorisation is personal. Employer authorisation does not entitle an unqualified employee to conduct litigation.
   
3. What happened to the £10,653 costs order?
   It was set aside on appeal; the High Court substituted no order as to costs.
   
4. Is the claim dead?
   No. Strike-out for abuse was refused; the defect had been rectified and the claim proceeds.
   
5. What does “question of fact and degree” mean in practice?
   Look at who drafts/approves pleadings, who decides strategy, and who assumes responsibility for formal steps.
   
6. What evidence proves solicitor control for costs?
   Supervisor approvals on documents, time-entry wording evidencing control, and a clear responsibility trail.