[2025] EWHC 2621 (KB)

As I have explained when setting out the legal framework, the question for me is whether there is "real and substantial advantage" of directing that quantum be dealt with separately in the Libel Claim.

I do not accept that it is premature to decide the question at this stage. The nature of the special damages claim is apparent from the pleadings.

I have considered the issue by reference to the eight factors identified in Electrical Water Recycling, and I will explain my reasoning by reference to those factors.

First of all, to summarise my conclusion, I have decided that there is a clear benefit to the special damages claim being heard subsequently, if the court finds in Mr Odey's favour at the liability stage of the Libel Claim. However, I am not persuaded that there is a clear benefit to directing that general damages, causation or injunctive relief should also be decided at the subsequent stage. I turn to the specific factors.