A High Court judge has suggested that a detailed costs budget should be submitted with any application for security for costs.
In the case of Agents' Mutual Ltd v Gascoigne Halman Ltd  EWHC 2315, Mr Justice Roth suggested that the Court should be provided with a full schedule showing how the sub totals under the various heads were arrived at, including the rates being charged and hours estimated.
The Defendant had already obtained security for costs in the sum of £500,000.00 and had submitted a schedule of £2.54m. The Defendant sought a further £1m but the Claimant was only prepared to offer £500,000.00.
The Defendant had prepared a one page summary that gave no indication of the hourly rates used and the time allocated between different fee earners.
Mr Justice Roth confirmed that, whilst the Defendant was not obliged to present a costs budget in the precise form of precedent H, the Court should expect to see a full schedule broken down into hourly rates and relevant phases.
On the basis of the information provided, Mr Justice Roth considered the costs against the Claimant's budget of £1.86m and concluded that the Defendant's costs should be little different to the Claimants'. A figure of £1.9m was adopted and it was considered fair to award security for 70% of that figure.
That came to a total of £1.33m with the Claimant paying an extra £830,000.00.