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This was the first time the Court of Appeal considered the conditions for a protective costs order in a public interest judicial review.

Challenge to new anti-bribery and anti-corruption procedures introduced by the Export Credit Guarantee Department.  This was the first time the Court of Appeal considered the conditions for a protective costs order in a public interest judicial review, here by an NGO claiming that it should have been consulted by the Export Credit Guarantee Department about guidelines for industry on bribery and corruption. The Court gave guidelines on the principles and practice of making proective Costs orders in public law cases.

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