Costs of costs budgeting
Woodburn v Thomas  EWHC B16 (Costs). Master McCloud.
Guidance about how the costs of budgeting should be dealt with in Precedent H and in any subsequent bill of costs. “ In my judgment (whether or not the Guidance [Precedent H Guidance Note] has been followed, albeit it was in this case), where a budget is approved or agreed, then the assumptions on which it was approved or agreed are the best guide as to how the relevant budgeting costs should be treated in the Bill, so as to avoid the difficulty of argument over the extent to which those budgeting costs may be subject to the CMC phase’s budget limit (thereby requiring “ good reason” if in excess of the budget) as opposed to or as well as the 2% cap imposed by PD 3 E 7.2(b)”.