PARTY AND PARTY COSTS

Time Limits

Mr. Justice Hogan held on 30th of July 2013 (Harte V Horan) that an Order for Costs only becomes enforceable after the Taxation has been completed (or the costs agreed, as the case may be). In particular, it was held that “taxation of costs is not part of the process of execution of a Judgement” and further that taxation is “the further completion of the Judgement process itself”. As a result, it may be argued in future matters (where the specifics are right), that time does not begin running on an Order for Costs (or possibly the entire Judgement) pursuant to the Statute of Limitations Act 1957 and/or pursuant to Order 42 Rule 23 RSC 1986, until the Taxation process is complete or the costs agreed, as the case may be.