Copying
1CBAM 7.14. CCFG 1.17.6.8.22Routine photocopying during the course of a case is an office overhead and cannot be recovered. However, larger quantities of photocopying do not fall within this description and as a result of judicial decisions, the LAA had issued guidance which was approved by the costs judge in
R v Brown:
2SCCO 215/10.In-house photocopying charges for routine copying are not recoverable since these constitute general office overheads. Solicitors may claim as a disbursement an outside agency’s charges for bulk photocopying, ie in excess of 500 pages (which is a cumulative figure per case) provided the assessor considers such a course of action reasonable, ie where the copies are so exceptionally bulky that it would not be reasonable to expect the solicitor’s normal office facilities to cope. An exception to this rule applies in cases where the Crown does not provide a second set of prosecution papers to the defence or where counsel is assigned in the Magistrates’ court in which case the 500 page limit does not apply.
In those circumstances both external and in-house copying charges can be recovered.
3See Landau and Cohen v Lord Chancellor’s Department (R v Abraham) [1999] 2 Costs LR 5. It is wise to obtain a CRM4 authority for volumes costing £100 or more. The collation of photocopying is part of profit costs.