Heron v TNT & Mackrell Turner Garrett
 1 WLR 1277;  4 Costs L.R. 551
Consideration by the Court of Appeal of whether a judge had been right to refuse an employer’s application for a non-party costs order against its employee’s solicitors, instructed on a CFA, in personal injury claim he had brought against them. The employers had not shown that in failing to obtain ATE insurance for the employee the solicitors had become a “real party” to the litigation.