An offer of compromise in the Court of Appeal for the same dollar amount as the judgment below constitutes a real compromise where the effect is to forego interest on the judgment sum, provided the amount of interest foregone is not token or nominal. The means of the offeror and the prospects of success on appeal are relevant to assessing whether the compromise is real. An offer is 'made' for the purposes of Part 52A rule 22(4) only when actually received by the offeree.
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