The Court of Appeal has upheld the decision not to allow a claim on behalf of an intestate's estate to proceed. A claimant in the capacity of administrator derives the title to sue solely from the grant of representation, unlike an executor, whose title to sue derives from the will. The claim was a nullity in the absence of a grant of representation and CPR 19.8(1) could not apply to it (Millburn-Snell v Evans (2011).