“ … Henderson v Henderson abuse of process, as now understood, although separate and distinct from cause of action estoppel and issue estoppel, has much in common with them. The underlying public interest is the same: that there should be finality in litigation and that a party should not be twice vexed in the same matter. This public interest is reinforced by the current emphasis on efficiency and economy in the conduct of litigation, in the interests of the parties and the public as a whole. The bringing of a claim or the raising of a defence in later proceedings may, without more, amount to abuse if the court is satisfied (the onus being on the party alleging abuse) that the claim or defence should have been raised in the earlier proceedings if it was to be raised at all.”
“ … an appellate court will be reluctant to interfere with the decision of the judge in the judgment he reaches on abuse of process by the balance of the factors; it will generally only interfere where the judge has taken into account immaterial factors, omitted to take account of material factors, erred in principle or come to a conclusion that was impermissible or not open to him.”
“On a question of abuse of process of this kind raised at a preliminary stage such as this, with no oral evidence, it seems to me that the appellate court is often likely to be, and in the present case is, in as good a position as the court below to assess whether the proceedings are or are not an abuse of process.”
“ … Even though the allegations which Mr Koshy raises are of such seriousness and importance, nonetheless the justice system is not bound to provide more than one opportunity to run these issues. That is because the courts have to strike a fair balance between the interests of Mr Koshy on the one hand and of the other parties and the general interest on the other hand. That fair balance in my judgment is struck once Mr Koshy has had one effective opportunity to put his case.”
“(i) Where A has brought an action against B, a later action against B or C may be struck out where the second action is an abuse of process. (ii) A later action against B is much more likely to be held to be an abuse of process than a later action against C. (iii) The burden of establishing abuse of process is on B or C or as the case may be. (iv) It is wrong to hold that because a matter could have been raised in earlier proceedings it should have been, so as to render the raising of it in later proceedings necessarily abusive. (v) The question in every case is whether, applying a broad merits based approach, A’s conduct is in all the circumstances an abuse of process. (vi) The court will rarely find that the later action is an abuse of process unless the later action involves unjust harassment or oppression of B or C.”
“1. The grounds which he gave for reaching his conclusion were contradicted by the evidence before him and/or were factors which he should not have taken into account: (i) The first and decisive factor on which he based his conclusion was that the claimants ‘whether on advice or otherwise, twice and with the benefit of advice consciously decided not to bring forward …’ in the first action the claims made in the present action. In so holding he disregarded the evidence of Mr and Mrs Barnett which was to the contrary effect. Their evidence was that up until the dismissal of the first action they believed that BFAL was the agent and the sole party entitled to sue and the joinder of the present claims was never suggested to them. Hence they did not at any point consciously decide to omit the present claims; they never considered it at all. (ii) the second factor was that six months elapsed between the dismissal of the first action and the commencement of the present action. The authorities establish that no criticism ought to be made of such delay. (iii) the third factor was the prejudice which would result to the defendant if the present action were to proceed. The prejudice the defendant complained of was (a) the amount of the costs of the first action in excess of the amount the defendant agreed that the claimant should pay in satisfaction of its costs liability, (b) the present alleged parlous state of the defendant’s finances and (c) the estimated legal fees of over£100,000 which the defendant would have to pay if the present proceedings were to proceed. The Master was in error in attaching any significant weight to these complaints because: First, it is wrong in principle to take prejudice to the defendant into account in deciding whether an action is an abuse of the process of the court; Secondly, even if such prejudice is to be taken into account, the Master paid no or no sufficient regard to the facts that the cost complaint relating to the first action was on any view irrelevant, that there was no evidence at all supporting the defendant’s assertion that its finances were in a parlous state, and that the defendant’s costs estimate was manifestly excessive. 2. In reaching his conclusion the Master paid no or no sufficient regard to the following: (i) that the omission of the present claims from the previous action was something for which Mr and Mrs Barnett were not personally responsible; (ii) that Mr and Mrs Barnett had at no stage acted deviously, tactically or in any manner deserving of criticism. 5. In reaching his conclusion the Master paid no or no sufficient regard to the fact that there had been no trial of the claims on their merits, and that the effect of his order was to shut out the claimants from ever being able to bring the claims forward to trial.” (i) The first and decisive factor on which he based his conclusion was that the claimants ‘whether on advice or otherwise, twice and with the benefit of advice consciously decided not to bring forward …’ in the first action the claims made in the present action. In so holding he disregarded the evidence of Mr and Mrs Barnett which was to the contrary effect. Their evidence was that up until the dismissal of the first action they believed that BFAL was the agent and the sole party entitled to sue and the joinder of the present claims was never suggested to them. Hence they did not at any point consciously decide to omit the present claims; they never considered it at all. (ii) the second factor was that six months elapsed between the dismissal of the first action and the commencement of the present action. The authorities establish that no criticism ought to be made of such delay. (iii) the third factor was the prejudice which would result to the defendant if the present action were to proceed. The prejudice the defendant complained of was (a) the amount of the costs of the first action in excess of the amount the defendant agreed that the claimant should pay in satisfaction of its costs liability, (b) the present alleged parlous state of the defendant’s finances and (c) the estimated legal fees of over£100,000 which the defendant would have to pay if the present proceedings were to proceed. The Master was in error in attaching any significant weight to these complaints because: First, it is wrong in principle to take prejudice to the defendant into account in deciding whether an action is an abuse of the process of the court; Secondly, even if such prejudice is to be taken into account, the Master paid no or no sufficient regard to the facts that the cost complaint relating to the first action was on any view irrelevant, that there was no evidence at all supporting the defendant’s assertion that its finances were in a parlous state, and that the defendant’s costs estimate was manifestly excessive. (i) that the omission of the present claims from the previous action was something for which Mr and Mrs Barnett were not personally responsible; (ii) that Mr and Mrs Barnett had at no stage acted deviously, tactically or in any manner deserving of criticism. The nature of this appeal