Administrators who maintain essential neutrality in proceedings challenging their appointment are entitled to a costs order in their favour, and the neutrality requirement does not preclude them from making costs applications including for personal costs orders. A party's failure to engage with or make counter-offers to Calderbank offers, combined with unsatisfactory conduct of litigation, supports a finding that refusal to accept a walk-away offer was unreasonable. The absence of prior warning of a special costs application weighs significantly against the ordering of indemnity costs in favour of administrators.
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