Where a Part 36 offer is made by the defendant and accepted by the claimant before proceedings are commenced, the claimant is unable to claim costs on the standard basis in accordance with CPR 36.10 because there are no proceedings. Where there is a disagreement about the costs to be paid by the defendant, the claimant’s Part 8 claim to recover costs falls to be dealt with under CPR 44.12A (costs-only proceedings) and not under the Part 36 regime (Udogaranya v Nwagw).