Costs – Offers to settle. The issue that arose in the present two appeals concerned the correct approach to costs in cases under the fixed costs regime in CPR Pt 45 s IIIA, concerning low value road traffic accident and employers' liability/public liability claims, where the defendant eventually accepted, after they should or could have done, the claimant's offer under CPR Pt 36. The Court of Appeal, Civil Division, held that correct interpretation of the rules was to say that, in a fixed costs case, CPR 36.20 applied where an offer was accepted late and CPR 36.13 did not apply at all.