‘Where a claimant in a QOCS case sues multiple defendants and recovers damages against one or more of them, any successful defendants with costs awards in their favour can enforce them against those damages, the Court of Appeal has decided in Cartwright v Venduct Engineering Limited [2018] EWCA Civ 1654 – but only if the damages are obtained pursuant to a court order rather than a settlement embodied in a Tomlin order.’
Hailsham Chambers, 18th July 2018