The case of Hallam v Natixis [CFI 016/2025] heard on 3 February 2026 brings some welcome clarity as to how the DIFC Court is likely to interpret the Practice Direction No.1 of 2025, which came into effect, without any prior notice or fanfare, on 1 October 2025 (the PD). The PD was intended to improve access to justice in employment disputes by introducing two general rules, namely, that: a) as a general principle the parties to an employment dispute should bear their own legal costs and b) that the default position on employment cases is that they should be heard in private. There has been considerable speculation as to how the PD will be applied and interpreted by the Courts and in one of the first cases dealing with the subject, Hallam v Natixis throws some helpful light on this and provides useful guidance for practitioners and litigants.
The Facts
Mr Hallam had pursued an employment claim in the CFI against his former employer, Natixis, and judgment was given for the Defendant on 19 September 2025, pre-dating the PD. In fact, the Claimant lost his case badly with 3 out of 4 of his claims being struck out and the fourth being dismissed subject to immediate judgment. Unsurprisingly, the Court ordered that Mr Hallam should pay Natixis’ costs, subject to costs submissions being submitted.
On 29 October 2025, Mr Hallam filed a No Costs Application which, inter alia, requested the Court to vary the order for costs so that no order for costs was substituted. Moreover, the...
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