Simcoe v Jacuzzi UK Group plc [2012] EWCA Civ 137; [2012] WLR (D) 35
“The date from which interest ran on an award of costs in the county court in favour of a successful litigant was, by reason of article 2 of the County Court (Interest on Judgment Debts) Order 1991, the date the order for costs was made, not the date on which costs were assessed or agreed. The discretion granted in making an award of costs by CPR r 40.8 did not apply and was ineffective in that court.”
WLR Daily, 16th February 2012
Source: www.iclr.co.uk