UK-wide - Personal Injury: Mainly Defendant Lawyers & Law Firms - UK - Chambers and Partners
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UK Guide

Personal Injury: Mainly Defendant — UK-wide

Overview

For as long as anyone can remember, personal injury claims have been conducted within an adversarial process. When the lawyers become involved each has a duty to do the best for their client. For many years the parties enjoyed a free-for-all as to how this was achieved, over which, prior to a trial, the courts had little control.

That all changed on 26 April 1999 with the introduction of the Civil Procedure Rules (CPR) under which the courts have managed cases and controlled the behaviour of parties both before and after the issue of proceedings. For a short time, following the case of Mitchell (2013) the degree of control became excessive and draconian penalties were handed out for relatively minor breaches of CPR. That glitch was ironed out through guidance handed down by the Court of Appeal in the case of Denton (2014), with judges retaining an overall discretion to see that justice is achieved between the parties.

The introduction of this discipline to the system has steadily forced parties to adopt far more robust business models with the emphasis on efficiency but quite rightly without sacrificing the quality of service to the client. However, more recently forces have been at work which threaten the increasingly fine balance between that quality and sustainable profit.

The first wave of attack came from fixed recoverable costs (FRC). In lower value claims, claimant lawyers are restricted to predetermined costs dependant on the stage reached in the proceedings and the amount recovered by the claimant. In those categories of work where claims handling is still economically viable there remains the potential for conflict between quality of service (borne out of training and experience) and profitability (linked to using less qualified but cheaper staff –‘dumbing down’). Lord Justice Jackson’s report of 31 July 2017 will almost inevitably lead to an extension of the classes of case covered by FRC.

In higher value PI claims (those above £100,000) FRC seem unlikely for the foreseeable future. There must still be a risk that this will come later. However, where proceedings were issued on or after 1 April 2013 claimant lawyers in personal injury cases have lost the benefit of conditional fee agreements under which a losing defendant could be liable for a success fee and after the event insurance premiums, which in extreme cases could see a claimant’s costs double. Then, since 22 April 2014 costs’ budgeting has resulted in the courts exerting downward pressure on claimant costs, not least through the application of ‘proportionality’ under which the amount of costs allowed must be proportionate to the damages recovered.

One welcome side effect of these more recent problems is that they have struck at the very heart of the adversarial system. A far larger proportion of claimant lawyers than before has seen the commercial sense in adopting a more consensual approach to claims handling with the emphasis on a cost effective, earlier settlement, rather than doing everything possible to drag the case on to a trial (with what used to be higher attendant costs). This in turn has resulted in the refinement of earlier informal protocols to produce a Guide to the Conduct of Cases Involving Serious Injury. At the heart of this is a collaborative approach by the parties with a view to early resolution of the claim.

This trend has suddenly been stalled by a new and unique threat in a form more sinister than anything previously experienced. On 27 February 2017 the then Lord Chancellor announced that the discount rate (DR) used to determine multipliers in high value personal injury claims was to be reduced from 2.5% to minus 0.75%. The change took effect on 20 March 2017 and was retrospective. This meant that a claim involving a 20-year old male, valued at £3m on 19 March was re-valued the following day at £8.5m, notwithstanding that such a valuation could not have been in the contemplation of either party when the claim was first made. This blew apart many reserves held by insurers and their reinsurers and the premiums collected suddenly bore no relationship to the risk that had arisen. With some employers’ liability and public liability policies the sums insured became woefully too low overnight, with the risk of underinsurance and the possible exposure to the insured of insolvency. Inevitably the insurance market reacted to this by increasing premiums, at a time when inflation was already beginning to become an issue. There was also a knock-on effect in that reinsurers (those who insure the insurer) and those who share the insurers’ exposure where claims reach higher limits also found that exposure dramatically increased overnight. This raised the prospect of those higher up the insurance ladder wishing to exercise control clauses to exert far more influence over the way a particular claim is handled than has previously been the case.

What of the relatively new spirit of cooperation between claimants and defendants? The answer: back to considering the best interests of the client as the primary duty of the lawyer. For defendants this meant calling off some settlement meetings and in many cases adopting a wait and see approach. The impact of the reduction in the DR was immediately brought to the attention of the government, which promised to carry out an urgent review. It thus seemed far better to delay settlements and (if possible) trials until there was an opportunity to ‘correct’ the DR. Claimants took the opposite view: push through as many cases as possible before any amendment to the DR produced less favourable outcomes. These positions were seen as short term but that did not factor in the decision to hold a general election.

At the time of writing there is no indication as to when a substantive response will be published. Until such time as the government addresses the issue of what is the appropriate DR (and incidentally when and how it should be set in the future) the uncertainty will remain and opposing parties will be forced to consider how higher value cases should be handled tactically. From a claimant perspective timing could be a major issue. A delayed settlement using the current DR will produce higher damages. The delay will also produce higher costs but the claimant’s lawyer will be less concerned about the proportionality of those costs. Wait too long, however, and a DR revised upwards could see huge sums wiped off the value of the claim.

No doubt the DR issue will be resolved in due course but not necessarily to the satisfaction of either side (which the government may view as the best result). What is of concern, particularly with Brexit simmering in the background, is whether parties will be faced with further changes, the short or long term impact of which will not have been properly thought out. It is difficult enough to plan business models when changes are flagged well in advance but the profession and its clients may continue to struggle if there are ill conceived external pressures on what in current government circles is clearly an unpopular area of business. Changes that have retrospective effect must be avoided if a consensual approach to claims handling is to be encouraged.

Contributed by Horwich Farrelly Solicitors

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BLM - Personal Injury: Mainly Defendant Department

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Band 1

第一等

Chambers Commentary (based on the Chambers research)

Basic facts about the department
- 112 partners
- 382 other qualified lawyers
- Office locations: Birmingham, Bristol, Leeds, Liverpool, London, Manchester, Southampton

What the team is known for Pre-eminent defendant-side personal injury practice routinely sought out for representation by leading insurers. Well equipped to handle the full range of matters, including catastrophic injury, Highways Act and sexual abuse cases. Additional expertise in handling multi-track industrial disease litigation.

Strengths One source says this is "a very impressive team. They are always looking for different approaches on how to settle a case and are very forward-thinking."

Work highlights Successfully defended Riverstone Insurance at trial and in the Court of Appeal against a claim arising out of a road traffic accident caused by an unidentified driver. The case was highly significant as a decision in the claimant's favour would have required considerable reinterpretation of the Road Traffic Act.

Represented LV= in a number of claims arising out of the deliberate use of an insured vehicle to kill and cause injury by a driver subsequently detained in a secure hospital.

Significant clients MS Amlin, North Somerset Council, QBE, Zurich Insurance, Direct Line.

Notable practitioners

The "outstanding" Andrew Hibbert is "probably one of the most experienced defendant insurance solicitors out there,” according to interviewees. He maintains a strong personal injury practice, regularly defending high-value catastrophic injury claims arising out of traffic collisions and other severe accidents.

Roger Brooks has extensive experience in handling the defence of complex personal injury cases arising from employer, public and RTA liability. He has notable expertise in the most severe kinds of personal injury, including brain and spinal injuries, amputations and fatal accidents.

Nicholas Pargeter heads the firm's national industrial disease team, and specialises in handling the strategic defence of major multi-defendant personal injury claims. He regularly advises leading insurers on complex cases concerning mesothelioma and other asbestos-linked conditions.

Michael Pether heads the firm's public sector defence group and specialises in litigation arising from highly sensitive claims of abuse and bullying. He regularly advises local authorities, religious organisations and schools, along with their insurers, in the wake of such claims. He also has additional expertise in employers' and public liability matters.

Consultant Terry Renouf offers clients the depth and breadth of his experience in managing multi-track personal injury claims. He is well versed in both catastrophic injury and industrial disease cases. Clients appreciate how he is "always happy to help."

The "excellent" Jenny Moates is a consultant with long-standing experience in personal injury matters. She continues to provide advice on cases of catastrophic injury and fatal accidents, with specialist expertise in claims relating to the rail industry.

Henry Bermingham is an experienced personal injury solicitor with comprehensive knowledge of litigation concerning public sector bodies. He focuses particularly on accident and injury claims that involve social services and highways.

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Clyde & Co LLP - Personal Injury: Mainly Defendant Department

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Band 1

第一等

Chambers Commentary (based on the Chambers research)

Basic facts about the department
- 35 partners
- 376 other qualified lawyers
- Office locations: London, Manchester

What the team is known for Stellar defendant team focusing on complex high-value claims, including those with international elements. Well equipped to handle the full range of personal injury matters, ranging from catastrophic accident and mesothelioma claims to occupational stress. Works with an enviable list of of major insurers, defending both group actions and substantial individual claims.

Strengths One client says: "They relate to us and know our business," adding that "they push back and challenge us on points, especially on historic claims. They take almost a personal interest, but always with the desire to help us."

Another describes the firm as "a go-to for technically difficult cases."

Work highlights Assisted AXA with quickly settling a combined claim of over £10 million after two passengers suffered severe injuries in a road traffic accident.

Represented Aviva Insurance and its insured, Workington Golf Club, after a member was struck by a golf ball while playing on the course. The claim for £250,000 was ultimately dismissed and all costs recovered.

Significant clients NFU Mutual, RSA, Allianz, Admiral Insurance, Chubb.

Notable practitioners

Sources praise Peter Walmsley as a "very sensible, forward-thinking and innovative” personal injury practitioner. He is particularly adept at handling high-value catastrophic injury and road accident claims, including those occurring outside the UK.

Peter Whitehead has over 30 years' experience in the personal injury market. He is a seasoned practitioner adept at defending insurers on high-value catastrophic injury claims, particularly those resulting from severe road traffic accidents.

Kevin Bitmead leads the casualty and healthcare team in London and has diverse personal injury expertise including a strong focus on catastrophic injury claims. He has key understanding of motor, employers' and public liability, among other areas.

Christopher Murray acts for clients in both the public and private sectors, including leading insurance companies and brokers. His expertise encompasses a broad range of complex injury matters relating to public liability, RTAs and domestic accidents.

Jennette Newman continues to take on a broad spread of personal injury work on behalf of both insurers and corporate clients, defending against claims of major loss and catastrophic injury, including fatalities. She also has considerable regulatory knowledge across a range of industries and often advises on cases with significant health and safety elements.

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DAC Beachcroft LLP - Personal Injury: Mainly Defendant Department

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Band 1

第一等

Chambers Commentary (based on the Chambers research)

Basic facts about the department
- Office locations: Bristol, Birmingham, Winchester, Leeds, London, Manchester, Newcastle, Newport

What the team is known for National firm housing a substantial team of experts who can defend everything from serious injury and industrial disease claims to suspected cases of fraud. A leading adviser to major insurers, and very capable of handling international matters. Particular expertise in motor claims, with additional knowledge of public and employers' liability. Bolstered by a number of recent partner additions to the Newcastle and London teams.

Strengths One client comments on the team's "exceptional customer focus, great attention to detail and wide range of technical capability."

Another says: "I know I can go to DAC and get a response no matter the question. They go the extra mile for us."

Work highlights Represented Zurich in a successful appeal concerning a settlement that was reopened upon evidence of fraud. The claimant was awarded almost £135,000 for an accident which he was later found to have exaggerated significantly. The case was taken to the Court of Appeal and then the Supreme Court, where it was ultimately decided that claimant should repay the majority of the damages awarded.

Defended AXA against an action brought by the family of an individual who died on falling out of a hotel window. The claim for £300,000 in damages was ultimately settled for £60,000.

Significant clients AVIVA Insurance, BAE Systems, NHS Litigation Authority, QBE Insurance, Allianz Insurance.

Notable practitioners

Deborah Bradley regularly advises leading insurance companies faced with public and employer's liability issues in the wake of catastrophic injury claims. Sources say: "She takes a very sensible view on where a claim is likely to go and makes it easier for everyone involved."

David Knapp recently joined the firm in London from Clyde & Co. He offers strong expertise in complex personal injury claims to both public and private sector clients. Sources describe him as a "very sensible" lawyer.

Sara May regularly handles cases of substantial loss, and leads the firm's team in this area. She regularly handles claims of the utmost severity and has particular focus on claims arising out of RTAs.

Andrew Parker focuses on strategic litigation matters, and has been involved in a wide range of cases that are of crucial significance to the industry. He has recently been significantly involved in judicial reviews concerning the costs associated with personal injury claims.

The "very impressive" Tania Sless handles a wide variety of catastrophic injury cases, including occupational disease and employers' liability claims. Clients report: "She is pragmatic and really understands our business."

Owen Rees counts a number of global insurers among his clients, advising them not only on specific catastrophic injury claims but also on strategic matters. He has a broad range of expertise but is particularly knowledgeable about brain and spinal injury claims related to motor accidents.

Solicitor advocate Duncan Rutter is a consultant in the firm's Winchester office. He has considerable experience handling complex, high-value injury claims on behalf of major insurers. Sources describe him as "very intellectual and very experienced."

The "excellent" Danielle Singer is a recent addition to the London claims team, having previously been at Clyde & Co. She maintains a strong practice defending insurance clients facing catastrophic brain and spinal injury claims. Sources describe her as a "sensible" and "non-confrontational" lawyer who just "gets on with it."

Sources rate Sally Yuill "very highly indeed" for her work on catastrophic injury cases, in which she represents insurers facing claims of the utmost severity. She is equally adept at handling claims concerning motor, public and employers' liability.

Consultant Andrew Scott is based in Leeds, and has a huge breadth of knowledge across matters of personal injury and associated insurance liabilities. His work has included cases of the highest severity including brain and spinal injuries, amputation, paraplegia and tetraplegia.

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DWF LLP - Personal Injury: Mainly Defendant Department

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Band 1

第一等

Chambers Commentary (based on the Chambers research)

Basic facts about the department
- 54 partners
- 176 other qualified lawyers
- Office locations: Bristol, Birmingham, Liverpool, London, Manchester, Edinburgh, Glasgow

What the team is known for Pre-eminent large loss practice which defends insurers against claims arising from catastrophic accidents, negligence and abuse. Also offers deep expertise in occupational illness matters, including noise-induced hearing loss. Proficient in handling cases involving accidents in the UK and abroad. Specialist expertise in handling fraudulent claims, including substantial motor insurance fraud rings.

Strengths Clients say: "We are delighted with their support. They are a firm that goes the extra mile."

One client adds: "DWF continue to impress with their knowledge and scope, particularly on claims from Europe.”

Work highlights Acted for QBE in connection with multiple claims arising out of a highly publicised coach crash in northern France in February 2012. The coach was carrying 49 school children and teachers back to the UK after a skiing trip when it came off the road, resulting in one fatality along with several other injuries.

Defended the Royal Liverpool Philharmonic Orchestra, along with its insurer RSA, against a claim brought by a musician for noise-induced hearing loss.

Significant clients Markerstudy, Chubb, Aviva, Travelers, DLG.

Notable practitioners

Graham Dickinson leads the large loss team in London and retains an extremely strong reputation for his work in catastrophic injury cases. He handles a wide array of personal injury litigation, including complex international claims and group actions. Sources describe him as "absolutely superb" and a "doyen" of the personal injury market.

Claire Bowler is head of the international claims team at DWF, and much of her practice is focused on claims concerning incidents abroad. She frequently represents global insurers in high-value cases relating to catastrophic injuries and fatal accidents.

Head of occupational health and casualty Derek Adamson is well versed in the insurance aspects associated with industrial disease and employers' liability cases. One source says: "He is highly experienced in mesothelioma and asbestos cases. He knows his way about them incredibly well."

Glyn Jones leads the catastrophic injury group across the firm and also heads the insurance team in Leeds. He combines his experience in both areas to advise insurance companies on high-value injury claims and associated policy issues.

Liverpool-based David Young has considerable expertise handling substantial catastrophic injury claims including amputations, multiple traumas, brain and spinal injuries. He regularly advises insurers on high-value cases of motor, employers' and public liability.

Paul Davies continues to handle a broad roster of personal injury matters, including motor and public liability matters. He is adept at managing high-value claims on behalf of leading insurers.

Steven King has an impressive breadth of knowledge regarding complex catastrophic injury cases, including international claims. He advises clients on large loss, high-value cases associated with public, motor and employers' liability, to name a few.

Mark Whittaker provides broad expertise in personal injury litigation and also advises on insurance coverage issues. His clients include insurance companies as well as public and local authorities.

Mark Fowles recently moved to join DWF in Bristol, having previously been at Browne Jacobson. He offers public sector clients a range of personal injury advice, and has specialist expertise in handling cases of abuse and psychiatric injury claims.

Ian Slater specialises in catastrophic injury cases, particularly those concerning traumatic brain and spinal injuries. He regularly takes on high-value claims that are highly complex in nature.

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Kennedys - Personal Injury: Mainly Defendant Department

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Band 1

第一等

Chambers Commentary (based on the Chambers research)

Basic facts about the department
- 40 partners
- 263 associates
- Office locations: Chelmsford, London

What the team is known for Market-leading defence practice skilled in representing major insurers and corporations in the full range of personal injury claims. Advises on everything from workplace accident and motor cases to child abuse claims. Notable expertise in claims arising in the travel and holiday industries.

Strengths One source says: "They've got good lawyers who are pragmatic and sensible in their approach."

A client reports: "They are steady and reliable – understated but they get the job done very efficiently."

Work highlights Represented Chubb and its insured, Merlin Entertainment Group, in relation to claims arising out of the highly publicised crash on the 'Smiler' ride at Alton Towers in June 2015. Also advised on the health and safety investigation that followed the incident.

Advised TUI UK on defence of a large group action of over 600 claims for food poisoning by guests on holiday at a resort in Mexico.

Significant clients Admiral Group, Canopius, Eddie Stobart, AXA, Virgin Holidays.

Notable practitioners

Mark Burton remains an authority on catastrophic injury claims, and heads the firm's UK practice in this area. He regularly handles high-value cases concerning injuries of the utmost severity, with a notable focus on traumatic brain injury. Sources describe him as a "tough cookie" who is "extremely robust" in representing his clients, with one calling him "the most skilled defendant solicitor I have come across."

Sources describe Tracy Head as "fantastic," adding that she is "superb with clients." Her practice spans an array of personal injury claims for domestic and international insurers as well as corporate clients. She regularly handles catastrophic injury cases along with claims for psychiatric injury.

Richard West leads the team in Chelmsford and has notable expertise in catastrophic injury matters, particularly those sustained in road accidents. He advises insurers, local authorities and self-insured businesses on liability issues and large loss claims, with key focus on cases of traumatic brain and psychiatric injury.

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Keoghs LLP - Personal Injury: Mainly Defendant Department

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Band 1

第一等

Chambers Commentary (based on the Chambers research)

Basic facts about the department
- Office locations: Bolton, Coventry

What the team is known for Stellar reputation for defending insurers and self-insured clients on catastrophic injury and occupational disease claims. Clients also rely on the firm's outstanding counter-fraud team for advice in case of suspected fraud and exaggeration. Particularly well established in the motor insurance industry.

Strengths Sources say: "There is a real culture across the firm of doing work to a very high standard."

Work highlights Represented Direct Line Group after 29 defendants made fraudulent compensation claims arising from nine alleged road traffic accidents. One of the claims advanced to trial and was ruled fraudulent, while the eight others were discontinued with significant recovery of damages and legal costs from the claimants.

Represented the insurer of a taxi company in a claim for over £8 million after an accident which left a 19-year-old pedestrian in a coma for six months, and subsequently with severe brain damage.

Significant clients Zurich, RSA, Hastings Direct, LV=, NFU Mutual.

Notable practitioners

The "excellent" Michael Renshaw recently joined Keoghs from BLM. He has extensive experience defending insurance companies and their clients against high-value claims regarding injuries of the utmost severity such as amputation, brain injury or paralysis. He focuses particularly on cases concerning RTAs.

Andrew Underwood is highly regarded by interviewees as "an excellent lawyer, who is very fair and realistic in his approach." He handles a range of catastrophic injury claims for leading insurers in the market, particularly in the motor industry.

David Pugh continues to impress for the quality of his work on major industrial disease cases. He represents a range of insurance clients and government bodies in asbestos-related claims, and also advises on significant test litigation and appeals.

Ken Young has considerable expertise in motor, public and employers' liability matters. He regularly defends high-value claims for traumatic brain and spinal injuries, and is also very experienced in chronic pain cases. Sources report that he "does a good job for his clients."

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Weightmans - Personal Injury: Mainly Defendant Department

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Band 1

第一等

Chambers Commentary (based on the Chambers research)

Basic facts about the department
- 73 partners
- 380 other qualified lawyers
- Office locations: Birmingham, London, Liverpool

What the team is known for Substantial and highly regarded personal injury team instructed by some of the country's largest insurers to defend the full range of injury and disease cases. Other areas of activity include the investigation and litigation of claims for fraud and exaggeration. Advises on the full spectrum of catastrophic injury claims as well as injuries arising from alleged negligence and abuse.

Strengths A source notes the team's "breadth of experience and the depth in its partners and associates."

Another says: "They are a good firm – a steady player that is very well regarded in the market."

Work highlights Acted for Co-operative Insurance and an insured individual after a road accident which left a cyclist with a severe brain injury and in a minimally conscious state. The claim ultimately settled with contributory negligence and reverse indemnity agreed.

Successfully defended Denbighshire County Council against claims brought by the family of a teenage school pupil who committed suicide following a meeting with a school child protection officer.

Significant clients Ageas, MIB, Sabre, Covéa Insurance, AIG, Van Ameyde.

Notable practitioners

David Holt is a respected personal injury practitioner who frequently takes the lead on cases concerning substantial loss. He is highly experienced in catastrophic injury claims with a focus on severe head and spinal injuries.

Victoria Coleman handles a broad range of serious injury claims including amputations, head and spinal injuries, tetraplegia and paraplegia. Clients say she is "knowledgeable and proactive," while another source describes her as a "very good technical lawyer."

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Horwich Farrelly Solicitors - Personal Injury: Mainly Defendant Department

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Band 2

第二等

Chambers Commentary (based on the Chambers research)

Basic facts about the department
- 20 partners
- 22 other qualified lawyers
- Office locations: London, Manchester, Cardiff, Southampton, Sheffield

What the team is known for Considerable defendant-side personal injury offering with the ability to handle a significant range of employers', public and motor liability matters. Highly respected for its expertise in handling catastrophic injury claims, including those involving brain and spinal cord injuries. Experience covers injury arising from RTAs as well as cases of suspected motor insurance fraud.

Strengths Sources report: "They have a very impressive, high-end team in London."

Notable practitioners

Malcolm Henke remains "very well respected" as a seasoned practitioner acting for insurers in large and complex personal injury cases. He specialises in severe brain and spinal injuries sustained during RTAs.

Rod Evans adroitly handles high-value catastrophic injury claims on behalf of insurers, particularly in the motor industry. He also advises on suspected fraudulent claims. Sources praise him for "seeing the bigger picture, providing support and getting to the crux of a case quickly."

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Browne Jacobson LLP - Personal Injury: Mainly Defendant Department

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Band 3

第三等

Chambers Commentary (based on the Chambers research)

Basic facts about the department
- 23 partners
- 90 other qualified lawyers
- Office locations: London, Birmingham, Exeter, Nottingham

What the team is known for Regularly defends public sector clients against employers' and public liability claims. Historic abuse and asbestos exposure claims form a significant part of the group's practice. Offers notable expertise in claims of injury or neglect concerning children.

Strengths One client reports: "From start to finish, the service, response, advice and support was excellent."

Another adds: "They are an approachable, knowledgeable firm.”

Work highlights Defended Nottinghamshire County Council and its insurers in a Supreme Court appeal regarding claims that the council was vicariously liable for abuse suffered by the claimant while in the care of foster parents.

Successfully represented the London Borough of Enfield regarding a claim for £168,000 by a former school caretaker who alleged he had developed malignant mesothelioma after coming into contact with asbestos.

Significant clients Municipal Mutual Insurance, Gallagher Bassett International, Hiscox, Resolute Management, NPS Wales.

Notable practitioners

Susan Mabbott in Nottingham is a key contact at the firm.

About the Team (content provided by Browne Jacobson LLP)

  • Public sector expertise – particularly social care and health and the defence of insurance claims arising from those sectors - we are regarded as the “go to” firm for social care claims 
  • Niche commercial insurance – where our focus on complex claims or particular portfolios can deliver real benefits to our clients. They instruct us because of our bespoke, relationship driven, approach to their claims books
  •  Highway Authority claims – particularly with regard to the Code of Practice for highways management –we have led on the implementation of the new code for our clients
  • Deprivation of Liberty Safeguard claims – the unique synthesis between our health and social care teams means that we are market leaders in the defence of these claims arising from health and social care regimes
  • Particular expertise in handling injury claims of the utmost severity including spinal injuries, amputations, brain injury and PPO issues
  • Our bespoke and innovative training delivered either in person (Claims Clubs etc) or via videos really sets us apart. Clients appreciate we concentrate on the implications for their business rather than simply reciting or flagging changes in the law

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Langleys Solicitors LLP - Personal Injury: Mainly Defendant Department

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Band 3

第三等

Chambers Commentary (based on the Chambers research)

Basic facts about the department
- 8 partners
- 21 other qualified lawyers
- Office locations: Lincoln, York

What the team is known for Robust personal injury defendant practice, acting for insurers, public bodies and companies on a variety of motor and employers' and public liability claims. Routinely instructed on multimillion-pound claims, including catastrophic injury, occupational disease and abuse cases. Particularly adept at handling cases arising out of severe RTAs and accidents in the workplace.

Strengths A client says: "They tend to be my first choice as the quality of their work and the advice given is of an excellent quality."

Another adds: "They are passionate about what they do and they really care about their clients."

Work highlights Represented a subcontractor insured by RiverStone as the first defendant in a claim arising out of an accident on a newly constructed residential property. The claimant was a self-employed decorator who was working alone on site when he fell from a ladder and sustained severe spinal injuries.

Significant clients Tokio Marine Kiln, Pen Underwriting, Gateshead Council, NFU Mutual, Liberty Mutual Insurance.

Notable practitioners

Head of insurance David Thompson has valuable experience handling both high-value personal injury claims as well as associated coverage and policy disputes. He regularly advises on cases regarding traumatic brain and spinal injuries, particularly those sustained on the road. Clients speak highly of his "strategic sense" and dedication to his clients.

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Plexus Law - Personal Injury: Mainly Defendant Department

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Band 3

第三等

Chambers Commentary (based on the Chambers research)

Basic facts about the department
- 67 partners
- 325 other qualified lawyers
- Office locations: London, Manchester, Leeds, Evesham, Edinburgh

What the team is known for Solid team capable of advising defendants on the full range of industrial disease and personal injury claims. Represents an enviable roster of clients including leading insurers, public sector bodies and retailers. Able to advise on claims in the UK as well as those involving accidents abroad. Strong expertise in cases which involve complex employers' and public liability.

Strengths One client says: "They always go the extra mile to deliver for their clients – they align strategy to meet client demand and consistently offer advice around the changing legal landscape to inform claims strategy."

Another adds that the team is “always very diligent and good at getting back to me."

Work highlights Represented QBE and its insured, McGee Group, in a claim made by an employee who was severely injured while driving a tipper truck and was subsequently unable to return to work. The claim was dismissed at a liability.

Successfully defended Derbyshire County Council against a claim for significant damages by a man who suffered a traumatic brain injury after a motorcycle accident caused by allegedly defective road repairs. The claim was not pursued as the repairs complied with highway safety standards.

Significant clients DLG, Tesco, Balfour Beatty, Aspen, AIG.

Notable practitioners

Damon Burt heads the large loss practice and is particularly adept at handling substantial occupational disease claims. He also advises on a range of other employers' and public liability matters. Clients praise his ability to foster collaborative relationships with them, saying: "He really listens and effects change, it's not just lip service."

Philip Tracey advises leading insurers and their clients on a wide array of employers' liability matters, including industrial disease and stress at work claims. He also regularly takes on cases concerning severe sports injuries.

The "superb" Philip D'Netto has many years' experience acting for clients in the insurance industry, including insurance companies and Lloyd's syndicates. He is well thought of for his expertise in relation to catastrophic injury and large loss.

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Overview

For as long as anyone can remember, personal injury claims have been conducted within an adversarial process. When the lawyers become involved each has a duty to do the best for their client. For many years the parties enjoyed a free-for-all as to how this was achieved, over which, prior to a trial, the courts had little control.

That all changed on 26 April 1999 with the introduction of the Civil Procedure Rules (CPR) under which the courts have managed cases and controlled the behaviour of parties both before and after the issue of proceedings. For a short time, following the case of Mitchell (2013) the degree of control became excessive and draconian penalties were handed out for relatively minor breaches of CPR. That glitch was ironed out through guidance handed down by the Court of Appeal in the case of Denton (2014), with judges retaining an overall discretion to see that justice is achieved between the parties.

The introduction of this discipline to the system has steadily forced parties to adopt far more robust business models with the emphasis on efficiency but quite rightly without sacrificing the quality of service to the client. However, more recently forces have been at work which threaten the increasingly fine balance between that quality and sustainable profit.

The first wave of attack came from fixed recoverable costs (FRC). In lower value claims, claimant lawyers are restricted to predetermined costs dependant on the stage reached in the proceedings and the amount recovered by the claimant. In those categories of work where claims handling is still economically viable there remains the potential for conflict between quality of service (borne out of training and experience) and profitability (linked to using less qualified but cheaper staff –‘dumbing down’). Lord Justice Jackson’s report of 31 July 2017 will almost inevitably lead to an extension of the classes of case covered by FRC.

In higher value PI claims (those above £100,000) FRC seem unlikely for the foreseeable future. There must still be a risk that this will come later. However, where proceedings were issued on or after 1 April 2013 claimant lawyers in personal injury cases have lost the benefit of conditional fee agreements under which a losing defendant could be liable for a success fee and after the event insurance premiums, which in extreme cases could see a claimant’s costs double. Then, since 22 April 2014 costs’ budgeting has resulted in the courts exerting downward pressure on claimant costs, not least through the application of ‘proportionality’ under which the amount of costs allowed must be proportionate to the damages recovered.

One welcome side effect of these more recent problems is that they have struck at the very heart of the adversarial system. A far larger proportion of claimant lawyers than before has seen the commercial sense in adopting a more consensual approach to claims handling with the emphasis on a cost effective, earlier settlement, rather than doing everything possible to drag the case on to a trial (with what used to be higher attendant costs). This in turn has resulted in the refinement of earlier informal protocols to produce a Guide to the Conduct of Cases Involving Serious Injury. At the heart of this is a collaborative approach by the parties with a view to early resolution of the claim.

This trend has suddenly been stalled by a new and unique threat in a form more sinister than anything previously experienced. On 27 February 2017 the then Lord Chancellor announced that the discount rate (DR) used to determine multipliers in high value personal injury claims was to be reduced from 2.5% to minus 0.75%. The change took effect on 20 March 2017 and was retrospective. This meant that a claim involving a 20-year old male, valued at £3m on 19 March was re-valued the following day at £8.5m, notwithstanding that such a valuation could not have been in the contemplation of either party when the claim was first made. This blew apart many reserves held by insurers and their reinsurers and the premiums collected suddenly bore no relationship to the risk that had arisen. With some employers’ liability and public liability policies the sums insured became woefully too low overnight, with the risk of underinsurance and the possible exposure to the insured of insolvency. Inevitably the insurance market reacted to this by increasing premiums, at a time when inflation was already beginning to become an issue. There was also a knock-on effect in that reinsurers (those who insure the insurer) and those who share the insurers’ exposure where claims reach higher limits also found that exposure dramatically increased overnight. This raised the prospect of those higher up the insurance ladder wishing to exercise control clauses to exert far more influence over the way a particular claim is handled than has previously been the case.

What of the relatively new spirit of cooperation between claimants and defendants? The answer: back to considering the best interests of the client as the primary duty of the lawyer. For defendants this meant calling off some settlement meetings and in many cases adopting a wait and see approach. The impact of the reduction in the DR was immediately brought to the attention of the government, which promised to carry out an urgent review. It thus seemed far better to delay settlements and (if possible) trials until there was an opportunity to ‘correct’ the DR. Claimants took the opposite view: push through as many cases as possible before any amendment to the DR produced less favourable outcomes. These positions were seen as short term but that did not factor in the decision to hold a general election.

At the time of writing there is no indication as to when a substantive response will be published. Until such time as the government addresses the issue of what is the appropriate DR (and incidentally when and how it should be set in the future) the uncertainty will remain and opposing parties will be forced to consider how higher value cases should be handled tactically. From a claimant perspective timing could be a major issue. A delayed settlement using the current DR will produce higher damages. The delay will also produce higher costs but the claimant’s lawyer will be less concerned about the proportionality of those costs. Wait too long, however, and a DR revised upwards could see huge sums wiped off the value of the claim.

No doubt the DR issue will be resolved in due course but not necessarily to the satisfaction of either side (which the government may view as the best result). What is of concern, particularly with Brexit simmering in the background, is whether parties will be faced with further changes, the short or long term impact of which will not have been properly thought out. It is difficult enough to plan business models when changes are flagged well in advance but the profession and its clients may continue to struggle if there are ill conceived external pressures on what in current government circles is clearly an unpopular area of business. Changes that have retrospective effect must be avoided if a consensual approach to claims handling is to be encouraged.

Contributed by Horwich Farrelly Solicitors

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Senior Statesperson

BLM

From the Chambers UK guide

Consultant Terry Renouf offers clients the depth and breadth of his experience in managing multi-track personal injury claims. He is well versed in both catastrophic injury and industrial disease cases. Clients appreciate how he is "always happy to help."

^ See whole ranking table

Eminent Practitioner

BLM

From the Chambers UK guide

The "excellent" Jenny Moates is a consultant with long-standing experience in personal injury matters. She continues to provide advice on cases of catastrophic injury and fatal accidents, with specialist expertise in claims relating to the rail industry.

^ See whole ranking table

Star Individuals

DWF LLP

From the Chambers UK guide

Graham Dickinson leads the large loss team in London and retains an extremely strong reputation for his work in catastrophic injury cases. He handles a wide array of personal injury litigation, including complex international claims and group actions. Sources describe him as "absolutely superb" and a "doyen" of the personal injury market.

^ See whole ranking table

Star Individuals

Horwich Farrelly Solicitors

From the Chambers UK guide

Malcolm Henke remains "very well respected" as a seasoned practitioner acting for insurers in large and complex personal injury cases. He specialises in severe brain and spinal injuries sustained during RTAs.

^ See whole ranking table

Star Individuals

BLM

From the Chambers UK guide

The "outstanding" Andrew Hibbert is "probably one of the most experienced defendant insurance solicitors out there,” according to interviewees. He maintains a strong personal injury practice, regularly defending high-value catastrophic injury claims arising out of traffic collisions and other severe accidents.

^ See whole ranking table

Star Individuals

Keoghs LLP

From the Chambers UK guide

Andrew Underwood is highly regarded by interviewees as "an excellent lawyer, who is very fair and realistic in his approach." He handles a range of catastrophic injury claims for leading insurers in the market, particularly in the motor industry.

^ See whole ranking table

Band 1

BLM

From the Chambers UK guide

Roger Brooks has extensive experience in handling the defence of complex personal injury cases arising from employer, public and RTA liability. He has notable expertise in the most severe kinds of personal injury, including brain and spinal injuries, amputations and fatal accidents.

^ See whole ranking table

Band 1

Kennedys

From the Chambers UK guide

Mark Burton remains an authority on catastrophic injury claims, and heads the firm's UK practice in this area. He regularly handles high-value cases concerning injuries of the utmost severity, with a notable focus on traumatic brain injury. Sources describe him as a "tough cookie" who is "extremely robust" in representing his clients, with one calling him "the most skilled defendant solicitor I have come across."

^ See whole ranking table

Band 1

Plexus Law

From the Chambers UK guide

The "superb" Philip D'Netto has many years' experience acting for clients in the insurance industry, including insurance companies and Lloyd's syndicates. He is well thought of for his expertise in relation to catastrophic injury and large loss.  

^ See whole ranking table

Band 1

Weightmans

From the Chambers UK guide

David Holt is a respected personal injury practitioner who frequently takes the lead on cases concerning substantial loss. He is highly experienced in catastrophic injury claims with a focus on severe head and spinal injuries.

^ See whole ranking table

Band 1

Sintons

From the Chambers UK guide

Jamie McCabe of Sintons is highly reputed for his excellent personal injury practice, and regularly defends leading motor insurers against a broad array of catastrophic injury claims. Clients commend him for his "superlative tactical and negotiation skills."

^ See whole ranking table

Band 1

Nicholas Pargeter

BLM

From the Chambers UK guide

Nicholas Pargeter heads the firm's national industrial disease team, and specialises in handling the strategic defence of major multi-defendant personal injury claims. He regularly advises leading insurers on complex cases concerning mesothelioma and other asbestos-linked conditions.

^ See whole ranking table

Band 1

Clyde & Co LLP

From the Chambers UK guide

Sources praise Peter Walmsley as a "very sensible, forward-thinking and innovative” personal injury practitioner. He is particularly adept at handling high-value catastrophic injury and road accident claims, including those occurring outside the UK.

^ See whole ranking table

Band 1

Clyde & Co LLP

From the Chambers UK guide

Peter Whitehead has over 30 years' experience in the personal injury market. He is a seasoned practitioner adept at defending insurers on high-value catastrophic injury claims, particularly those resulting from severe road traffic accidents.

^ See whole ranking table

Band 2

DWF LLP

From the Chambers UK guide

Head of occupational health and casualty Derek Adamson is well versed in the insurance aspects associated with industrial disease and employers' liability cases. One source says: "He is highly experienced in mesothelioma and asbestos cases. He knows his way about them incredibly well."

^ See whole ranking table

Band 2

DWF LLP

From the Chambers UK guide

Claire Bowler is head of the international claims team at DWF, and much of her practice is focused on claims concerning incidents abroad. She frequently represents global insurers in high-value cases relating to catastrophic injuries and fatal accidents.

^ See whole ranking table

Band 2

Horwich Farrelly Solicitors

From the Chambers UK guide

Rod Evans adroitly handles high-value catastrophic injury claims on behalf of insurers, particularly in the motor industry. He also advises on suspected fraudulent claims. Sources praise him for "seeing the bigger picture, providing support and getting to the crux of a case quickly."

^ See whole ranking table

Band 2

DWF LLP

From the Chambers UK guide

Glyn Jones leads the catastrophic injury group across the firm and also heads the insurance team in Leeds. He combines his experience in both areas to advise insurance companies on high-value injury claims and associated policy issues.

^ See whole ranking table

Band 2

DAC Beachcroft LLP

From the Chambers UK guide

David Knapp recently joined the firm in London from Clyde & Co. He offers strong expertise in complex personal injury claims to both public and private sector clients. Sources describe him as a "very sensible" lawyer.

^ See whole ranking table

Band 2

DAC Beachcroft LLP

From the Chambers UK guide

Sara May regularly handles cases of substantial loss, and leads the firm's team in this area. She regularly handles claims of the utmost severity and has particular focus on claims arising out of RTAs.

^ See whole ranking table

Band 2

Clyde & Co LLP

From the Chambers UK guide

Jennette Newman continues to take on a broad spread of personal injury work on behalf of both insurers and corporate clients, defending against claims of major loss and catastrophic injury, including fatalities. She also has considerable regulatory knowledge across a range of industries and often advises on cases with significant health and safety elements.

^ See whole ranking table

Band 2

DAC Beachcroft LLP

From the Chambers UK guide

Andrew Parker focuses on strategic litigation matters, and has been involved in a wide range of cases that are of crucial significance to the industry. He has recently been significantly involved in judicial reviews concerning the costs associated with personal injury claims.

^ See whole ranking table

Band 2

BLM

From the Chambers UK guide

Michael Pether heads the firm's public sector defence group and specialises in litigation arising from highly sensitive claims of abuse and bullying. He regularly advises local authorities, religious organisations and schools, along with their insurers, in the wake of such claims. He also has additional expertise in employers' and public liability matters.

^ See whole ranking table

Band 2

DAC Beachcroft LLP

From the Chambers UK guide

The "very impressive" Tania Sless handles a wide variety of catastrophic injury cases, including occupational disease and employers' liability claims. Clients report: "She is pragmatic and really understands our business."

^ See whole ranking table

Band 2

DWF LLP

From the Chambers UK guide

Liverpool-based David Young has considerable expertise handling substantial catastrophic injury claims including amputations, multiple traumas, brain and spinal injuries. He regularly advises insurers on high-value cases of motor, employers' and public liability.

^ See whole ranking table

Band 3

Clyde & Co LLP

From the Chambers UK guide

Kevin Bitmead leads the casualty and healthcare team in London and has diverse personal injury expertise including a strong focus on catastrophic injury claims. He has key understanding of motor, employers' and public liability, among other areas. 

^ See whole ranking table

Band 3

DAC Beachcroft LLP

From the Chambers UK guide

Deborah Bradley regularly advises leading insurance companies faced with public and employer's liability issues in the wake of catastrophic injury claims. Sources say: "She takes a very sensible view on where a claim is likely to go and makes it easier for everyone involved."

^ See whole ranking table

Band 3

Plexus Law

From the Chambers UK guide

Damon Burt heads the large loss practice and is particularly adept at handling substantial occupational disease claims. He also advises on a range of other employers' and public liability matters. Clients praise his ability to foster collaborative relationships with them, saying: "He really listens and effects change, it's not just lip service.

^ See whole ranking table

Band 3

Weightmans

From the Chambers UK guide

Victoria Coleman handles a broad range of serious injury claims including amputations, head and spinal injuries, tetraplegia and paraplegia. Clients say she is "knowledgeable and proactive," while another source describes her as a "very good technical lawyer."

^ See whole ranking table

Band 3

Martin G Crabtree

Forbes

From the Chambers UK guide

Clients describe Martin Crabtree of Forbes as "diligent, prompt and very knowledgeable." He has many years' experience in personal injury claims and focuses particularly on public sector and sports-related matters, including catastrophic injury claims.

^ See whole ranking table

Band 3

DWF LLP

From the Chambers UK guide

Paul Davies continues to handle a broad roster of personal injury matters, including motor and public liability matters. He is adept at managing high-value claims on behalf of leading insurers.

^ See whole ranking table

Band 3

Trethowans LLP

From the Chambers UK guide

Kelvin Farmaner of Trethowans LLP handles a wide range of high-value personal injury claims. He focuses on catastrophic injuries resulting from RTAs but also has niche expertise in handling claims that relate to incidents involving livestock. Clients say: "He can always be relied upon to provide a constructive and analytical approach, showing a keen awareness of all the issues that may arise in the most complex cases."

^ See whole ranking table

Band 3

Wansbroughs Solicitors

From the Chambers UK guide

"Good operator" Rob Hams of Wansbroughs Solicitors has extensive experience with the public sector, and regularly defends local authorities and other bodies on a range of personal injury claims, including those relating to social care. He also handles significant stress at work cases.

^ See whole ranking table

Band 3

Kennedys

From the Chambers UK guide

Sources describe Tracy Head as "fantastic," adding that she is "superb with clients." Her practice spans an array of personal injury claims for domestic and international insurers as well as corporate clients. She regularly handles catastrophic injury cases along with claims for psychiatric injury. 

^ See whole ranking table

Band 3

DWF LLP

From the Chambers UK guide

Steven King has an impressive breadth of knowledge regarding complex catastrophic injury cases, including international claims. He advises clients on large loss, high-value cases associated with public, motor and employers' liability, to name a few.

^ See whole ranking table

Band 3

Keoghs LLP

From the Chambers UK guide

David Pugh continues to impress for the quality of his work on major industrial disease cases. He represents a range of insurance clients and government bodies in asbestos-related claims, and also advises on significant test litigation and appeals.

^ See whole ranking table

Band 3

DAC Beachcroft LLP

From the Chambers UK guide

Owen Rees counts a number of global insurers among his clients, advising them not only on specific catastrophic injury claims but also on strategic matters. He has a broad range of expertise but is particularly knowledgeable about brain and spinal injury claims related to motor accidents.

^ See whole ranking table

Band 3

DAC Beachcroft LLP

From the Chambers UK guide

Solicitor advocate Duncan Rutter is a consultant in the firm's Winchester office. He has considerable experience handling complex, high-value injury claims on behalf of major insurers. Sources describe him as "very intellectual and very experienced."

^ See whole ranking table

Band 3

DAC Beachcroft LLP

From the Chambers UK guide

The "excellent" Danielle Singer is a recent addition to the London claims team, having previously been at Clyde & Co. She maintains a strong practice defending insurance clients facing catastrophic brain and spinal injury claims. Sources describe her as a "sensible" and "non-confrontational" lawyer who just "gets on with it."

^ See whole ranking table

Band 3

Bevan Brittan

From the Chambers UK guide

Paul Taverner heads the insurance team at Bevan Brittan and is adept at handling high-value personal injury cases, with particular focus on catastrophic head and spinal injury cases. Clients describe him as "approachable and knowledgeable," and speak highly of his "excellent communication skills."

^ See whole ranking table

Band 3

DWF LLP

From the Chambers UK guide

Mark Whittaker provides broad expertise in personal injury litigation and also advises on insurance coverage issues. His clients include insurance companies as well as public and local authorities.

^ See whole ranking table

Band 3

Keoghs LLP

From the Chambers UK guide

Ken Young has considerable expertise in motor, public and employers' liability matters. He regularly defends high-value claims for traumatic brain and spinal injuries, and is also very experienced in chronic pain cases. Sources report that he "does a good job for his clients."

^ See whole ranking table

Band 3

DAC Beachcroft LLP

From the Chambers UK guide

Sources rate Sally Yuill "very highly indeed" for her work on catastrophic injury cases, in which she represents insurers facing claims of the utmost severity. She is equally adept at handling claims concerning motor, public and employers' liability.

^ See whole ranking table

Band 4

BLM

From the Chambers UK guide

Henry Bermingham is an experienced personal injury solicitor with comprehensive knowledge of litigation concerning public sector bodies. He focuses particularly on accident and injury claims that involve social services and highways.

^ See whole ranking table

Band 4

Pitmans LLP

From the Chambers UK guide

Ferhat Choudri of Pitmans LLP has considerable experience handling high-value personal injury claims and associated insurance matters. He focuses on catastrophic injury and fatality claims arising out of RTAs as well as advising on employers' and public liability matters. Clients say: "He is extremely knowledgeable, always turns things around very quickly and keeps us well informed."

^ See whole ranking table

Band 4

CMS

From the Chambers UK guide

Carl Dray of CMS provides both corporate and public sector clients with a range of advice regarding employers' liability matters. He is particularly well versed in industrial disease cases, including high-value claims for mesothelioma and other asbestos-related illnesses. 

^ See whole ranking table

Band 4

DWF LLP

From the Chambers UK guide

Mark Fowles recently moved to join DWF in Bristol, having previously been at Browne Jacobson. He offers public sector clients a range of personal injury advice, and has specialist expertise in handling cases of abuse and psychiatric injury claims.

^ See whole ranking table

Band 4

Christopher Murray

Clyde & Co LLP

From the Chambers UK guide

Christopher Murray acts for clients in both the public and private sectors, including leading insurance companies and brokers. His expertise encompasses a broad range of complex injury matters relating to public liability, RTAs and domestic accidents.

^ See whole ranking table

Band 4

Keoghs LLP

From the Chambers UK guide

The "excellent" Michael Renshaw recently joined Keoghs from BLM. He has extensive experience defending insurance companies and their clients against high-value claims regarding injuries of the utmost severity such as amputation, brain injury or paralysis. He focuses particularly on cases concerning RTAs.

^ See whole ranking table

Band 4

DAC Beachcroft LLP

From the Chambers UK guide

Consultant Andrew Scott is based in Leeds, and has a huge breadth of knowledge across matters of personal injury and associated insurance liabilities. His work has included cases of the highest severity including brain and spinal injuries, amputation, paraplegia and tetraplegia.

^ See whole ranking table

Band 4

DWF LLP

From the Chambers UK guide

Ian Slater specialises in catastrophic injury cases, particularly those concerning traumatic brain and spinal injuries. He regularly takes on high-value claims that are highly complex in nature.

^ See whole ranking table

Band 4

Langleys Solicitors LLP

From the Chambers UK guide

Head of insurance David Thompson has valuable experience handling both high-value personal injury claims as well as associated coverage and policy disputes. He regularly advises on cases regarding traumatic brain and spinal injuries, particularly those sustained on the road. Clients speak highly of his "strategic sense" and dedication to his clients.

^ See whole ranking table

Band 4

Plexus Law

From the Chambers UK guide

Philip Tracey advises leading insurers and their clients on a wide array of employers' liability matters, including industrial disease and stress at work claims. He also regularly takes on cases concerning severe sports injuries. 

^ See whole ranking table

Band 4

Herbert Smith Freehills

From the Chambers UK guide

Howard Watson of Herbert Smith Freehills has a huge amount of experience advising on personal injury claims, including both catastrophic injury and occupational disease matters. He is adept at handling high-value individual claims as well as complex group actions.

^ See whole ranking table

Band 4

Kennedys

From the Chambers UK guide

Richard West leads the team in Chelmsford and has notable expertise in catastrophic injury matters, particularly those sustained in road accidents. He advises insurers, local authorities and self-insured businesses on liability issues and large loss claims, with key focus on cases of traumatic brain and psychiatric injury.

^ See whole ranking table

Up and Coming

Trethowans LLP

From the Chambers UK guide

Bethany Blamire of Trethowans LLP handles a wide range of personal injury claims on behalf of domestic and international insurers. Her practice encompasses RTAs along with high-value public and employers' liability cases. Sources praise her attention to detail and the high quality of her advice.

^ See whole ranking table