Always well prepared and quickly gets to the key issues of the matter.Craig Johnson, Keoghs
Hannah represents both claimants and defendants in a variety of areas including road traffic accidents, employer’s liability, slipping and tripping claims and occupiers’ liability.
Hannah undertakes a variety of multi track work in the High Court and County Court.
As well as attending trials, applications, CCMCs and JSMs Hannah has an extensive personal injury paperwork practice. She regularly drafts pleadings, schedules of loss and counter schedules in claims pleaded over £1,000,000, drafts questions to experts and advises on liability, causation and quantum.
Hannah’s ongoing cases include:
Howes v Harford Attachments Limited (2018)
Fatal accident claim pleaded at £200,000 arising out of a fire at the defendant’s premises. Upon receipt of the counter schedule the parties were able to negotiate a sensible settlement that the court was happy to approve. Hannah represented the defendant.
Bartley v Francis (2017)
Hannah drafted the counter schedule for the defendant in this spinal injury claim where the claimant sustained complete tetraplegia following a cycling accident. The main issues between the parties were future care, accommodation and life expectancy. Matter settled at JSM by Alan Jeffreys QC.
Killeen v Jones (2017)
In a claim brought by an Olympic cyclist Hannah represented the defendant. The claimant had been knocked off his bike by the defendant reversing out of his drive. He was claiming substantial figures for loss of earnings and sponsorship money despite having fractured his ankle at the London Olympics the previous year. The counter schedule denied causation of the losses. The parties managed to settle the claim prior to trial.
Wilkinson v Kharytonau (October 2017)
Successfully defended a claim brought by a young pedestrian who was hit by D’s motorbike as crossing the New Kent Road with stationary traffic in one lane. Although it was found D should have slowed down on approaching the pedestrian crossing the claim failed on the basis of causation as C moved out from behind the stationary bus so quickly the accident could not have been avoided even if D going 20mph.
Eugene v Ladenika (August 2017)
Obtained a finding of fundamental dishonesty as well as a referral to the Attorney General in a case where liability was admitted but D successfully challenged causation of C’s injuries. In depth cross examination on the various accounts C had given of her injuries and the medical records caused the judge to comment that there was no doubt that C was lying.
Bostock v East Midlands Trains Ltd (August 2016)
C slipped over on a frozen puddle in the car park at a train station hitting his back and head. Whilst the claim was not high value the claim itself was of significance to East Midlands as it would determine the adequacy of their entire winter maintenance plan. Successfully defended the case at trial on the basis that it was reasonable to prioritise gritting certain areas first and could not eliminate all risks.
H v Luton and Dunstable Hospital NHS Foundation Trust (QBD, 7th March 2016)
Settled fatal accident clinical negligence claim on behalf of the estate and dependants. EH attended Luton and Dunstable hospital for a laparoscopic nephrectomy in 2012 during which one of her main arteries was severed but this was not noticed. EH required a further emergency operation and she passed away two days after the initial operation. The main head of loss was for loss of services that EH provided her four children and partner. A settlement of £200,000 was reached. The settlement and appointment were approved in the QBD.
Bourne v Poznyak (2015)
Reduced a successful party’s costs by 50% for failure to engage in mediation.
Khoroshani v QBE Insurance Ltd (2015)
Reduced a credit hire claim of over £30,000 to under £17,000 by successfully arguing that as the vehicle was driveable there was no need for hire to start until the claimant's car was actually ready to be repaired.
Mahmud v Lords Breakdown & Recovery Ltd (2014)
Successfully argued that a taxi driver could only claim his daily loss of profit rather than the much higher daily credit hire rate. Also successfully argued that the claimant failed to provide full financial disclosure and therefore was barred from relying on impecuniosity in respect of period and therefore should have replaced his car within 25 days of the engineer's report declaring it a total loss.
Hardy v Chapple (2014)
Successfully defended a claim at first instance representing a car driver who had pulled out of a minor road turning right and collided with a motorbike that was overtaking stationary traffic that had let the defendant out. It was found that the car driver did all he could in the circumstances and this was upheld on appeal.
T (A child) v Cleveland Police (2013)
Succeeded in a claim where a 15 year old boy was running across a road to catch a bus and did not see a police van that was turning into the junction. Liability was split 65:35, beating the claimant's own Part 36 offer.
If you would like to instruct Hannah Saxena or would like help or advice in doing so, please call and talk to our excellent clerking team, led by senior clerk Alan Kilbey MBE. Our phone number is +44 (0)20 7583 9241. Alternatively, please email us at email@example.com
For more information about our clerking team, please click here for the clerks page.
“Always well prepared and quickly gets to the key issues of the matter.”
Craig Johnson, Keoghs
“Hannah is, without doubt, a talent. Her attention to detail, her forensic examination of evidence and her preparation is second to none. Whether it be a trial or an interim application, she gives every case her full attention. You can be sure that your case is in safe hands if Hannah is instructed. She is personal, friendly and approachable. I would highly recommend her.”
Anne Chapman, DWF