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What
The latest Senior Courts Costs Office Guide 2025 was published recently, on Tuesday 21 October 2025, and anyone and everyone involved in a detailed costs assessment should read the Guide.
Why (So What)
The Senior Courts Costs Office (SCCO) carries out detailed assessments of costs in the civil courts of England and Wales, from the County Court to the Court of Appeal. The Guide not only explains in full detail what court users need to know to bring and respond to proceedings in the SCCO but, importantly, the court’s approach to how things should (and even must) be done. This report focuses on Section 11 only of the Guide, providing commentary on the key battleground of written submissions: points of dispute and replies. Ultimately, if the format of those written submissions is not right, you could lose the opportunity to make your point.
How to prepare submissions: the key battleground (format)
The Guide develops upon the rules and set out that the SCCO expects that:
• Points of dispute should be short and to the point and should follow as closely as possible Precedent G of the Schedule of Costs Precedents annexed to the Part 47 Practice Direction.
• If there are any matters of principle which require decision before individual items in the bill are addressed, these should be identified and then any specific points should be set out, stating concisely the nature and grounds of dispute. Once a point has been made it should not be repeated but the item numbers where the point arises should be inserted in the left-hand box as shown in Precedent G.
• Points of Dispute prepared in response to electronic bills should, so far as practicable, categorise the items objected to (for example by reference to particular Legal Team Members, tasks, activities, or communications) to enable the court to use the bill’s filtering function to isolate those items and make decisions quickly and efficiently.
In turn, Replies to Points of Dispute must be limited to points of principle and concessions only and should not contain general denials, specific denials or standard form responses (Part 47 Practice Direction, (para. 12.1)).
Peak comment
The drafting of written submissions such as points of dispute and replies is plainly a specialist task. Not getting it right could prove costly, for either party.
Luckily, Peak Costs is an expert in written advocacy, and we’re here to help. So, get in touch.
For further information contact David Hughes here.
Quick-read
• What: SCCO Guide recently published setting out its expectations as to how things are done, including the drafting of PoDs/Replies.
• So What: Getting it wrong can prove costly.
• How to avoid problems and pitfalls: Instruct Peak, experts in drafting PoD/Replies.
