31 July 2026 / Amy Dunkley

Issue: 8172 / Categories: Features , Profession , Costs , Procedure & practice , CPR

Costs after costs

Amy Dunkley considers where, why & to whom the courts will grant security for costs in detailed assessment proceedings

Covers Magomedov & Ors v Rabinovich & Ors, which held the court conducting detailed assessment does not have jurisdiction to grant security for costs.
The case distinguishes defendants’ claims from Solicitors Act 1974 proceedings by clients.
Magomedov avoids addressing the key question of whether detailed assessment proceedings are a separate ‘claim’ for CPR purposes.

So, your claim has been successful and costs of the action have been awarded in your favour, and you have obtained an order for security on those costs; but what about determining the precise amount the paying party must pay the winner?

Challenging a costs bill via detailed assessment can itself attract substantial costs. A key question is: can a party facing such a challenge obtain an order for security for those costs from the court conducting the assessment? Based on the recent decision in Magomedov & Ors v Rabinovich & Ors [2026] EWHC 962 (SCCO), the answer is no.

Jurisdiction

CPR 25.26(1) states:

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Costs after costs

Issue: 8172 / Categories: Features , Profession , Costs , Procedure & practice , CPR

Amy Dunkley considers where, why & to whom the courts will grant security for costs in detailed assessment proceedings

Covers Magomedov & Ors v Rabinovich & Ors, which held the court conducting detailed assessment does not have jurisdiction to grant security for costs.
The case distinguishes defendants’ claims from Solicitors Act 1974 proceedings by clients.
Magomedov avoids addressing the key question of whether detailed assessment proceedings are a separate ‘claim’ for CPR purposes.