“… while raising a new ground of appeal now is not ‘very late’ in the sense of jeopardising a hearing date, it is extremely late in all other senses as the appeal has been running many years …” 25. Not only is the Application late but it is also contrary to the contemporaneous documentation, the Statement of Main Terms and Conditions of Employment (see paragraph 9, above) and a complete volte face from the case that IPS originally sought to advance. Although the interpretation and effect of that document is a matter for the Tribunal, as Carr J observed at [36] in Quah this might be enough in itself for the Application to be rejected. 26. In so far as IPS seeks to blame its previous advisers for not advancing the grounds of appeal on which it now seeks to rely, as Ward LJ observed, at 1675, in Hytec Information Systems v Coventry City Council[1997] 1 WLR 666 (which was not cited by either party), when considering the question of whether a litigant’s case should be struck out for breach of an “unless” order that was said to be the fault of counsel rather than the litigant itself: “ Ordinarily this court should not distinguish between the litigant himself and his advisers. There are good reasons why the court should not: firstly, if anyone is to suffer for the failure of the solicitor it is better that it be the client than another party to the litigation; secondly, the disgruntled client may in appropriate cases have his remedies in damages or in respect of the wasted costs; thirdly, it seems to me that it would become a charter for the incompetent (as Mr MacGregor eloquently put it) were this court to allow almost impossible investigations in apportioning blame between solicitor and counsel on the one hand, or between themselves and their client on the other.” 27. In Asiana Judge Mosedale said: “30. The appellant’s case that it was not to be blamed for its representative’s errors rested on the CPR and the Upper Tribunal decision in O’Flaherty[2013] UKUT 161 (TCC) where the Upper Tribunal cited Sayers v Clarke Walker [2002] I WLR 3095 which pointed out that the CPR required the court to consider whether the failure to comply was caused by the party or its legal representative and that therefore it was a ‘relevant factor that the failure to comply was caused by the party’s legal representative and not by the party himself.’ 31. I am of course bound by what the Upper Tribunal said. Nevertheless, I would point out that where the fault lay with the representative it was only said to be a ‘relevant’ factor and not that it was necessarily an exonerating factor. It is difficult to see how it could be an exonerating factor save in exceptional circumstances: a party is responsible for how it conducts litigation; that includes responsibility for the actions of its representative whom it has chosen to appoint. Moreover, while the non-compliant party may well feel aggrieved if it is let down by its representative, it by no means follows that the errors of one party’s representative should be visited upon the other party who had no choice over who its opponent appointed as representative and certainly has no rights to sue his opponent’s representative in contract or negligence. The Tribunal is called upon to do justice between the parties and I struggle to see how it can be just to visit the errors of one party’s representative on the other party, which is in practice may be the result if a party is forgiven its non-compliance arising from its own representative’s failures.”