In Harris and another v Moat Housing Group South Ltd – Butterworths Law Direct 20.12.07 the court emphasised thatCPR 47.6 clearly provides that detailed assessment proceedings are commenced by the receiving party serving both a notice of commencement and 'the' bill. Accordingly, if the receiving party is entitled to recover his costs of instructing more than one solicitor, then para 4.2 (2) of the Costs Practice Direction requires him to include the costs of each solicitor separately in the bill.

If the receiving party fails to include the costs of his previous solicitor in the bill of costs, and the costs judge completes his assessment of costs without regard to those costs of the previous solicitor and proceeds to a final certificate, or there is a settlement of the bill, the receiving party cannot claim a further assessment or recover more than the amount agreed.