Littlestone and others v Macleish [2016] EWCA Civ 127
‘An admitted payment on account of a claim following a Part 36 offer to settle a claim of a higher amount was, in the absence of contrary agreement, made as much on account of the Part 36 offer as on account of the full sum claimed. It would be an absurdity for a defendant to be bound to pay an aggregated total of a Part 36 offer and an admissions payment that was larger than the total sum claimed (paras 23–24).’
WLR Daily, 10th March 2016
Source: www.iclr.co.uk