ADGM Case Note

Indemnity Costs After Summary Judgment in the ADGM — Rules 198 and 199 Applied

By Shuhail Ahamed · Counsel — Disputes & Corporate · 8 min read
Representative matter. This case note concerns a matter in which Noura Almaazmi Advocates & Legal Consultancy acted for the successful fourth defendant. Private individuals are anonymised. It is general commentary on ADGM procedure and does not constitute legal advice on any specific matter.

Case at a glance

Court
ADGM Court of First Instance — Real Property Division
Case number
ADGMCFI-2025-283 (costs following summary judgment reported at [2026] ADGMCFI 0005)
Judge
Justice Paul Heath KC
Registrar
Linda Fitz-Alan
Parties
A restaurant operator (anonymised) (claimant) v a landlord, a holding company, a facilities-management company and A real estate management company (our client) (defendants)
Decision date
15 April 2026
Status
Summary judgment for the defendants; a six-figure indemnity costs award to our client and its co-defendant, and a smaller standard-basis award to a third defendant
Our role
acted for the successful fourth defendant

Winning summary judgment is one thing; recovering what it cost you is another. In this April 2026 ADGM costs judgment — in which our team acted for a successful defendant — the Court awarded indemnity costs to the arm’s-length defendants and only standard costs to a defendant connected to a claim still running. The difference turned on the claimant’s conduct of its case, and on who was really at risk of duplicated work.

1. Where the costs question arose

A restaurant operator sued four defendants over a failed fit-out, claiming in total about USD 1.09 million, roughly a third of which was a claim for moral damages. Three defendants applied for summary judgment; in February 2026 the Court granted it, holding the claims against them had no real prospect of success. Costs were reserved and determined separately.

2. The two bases — and the test that separates them

Rule 199 allows indemnity costs that are “reasonably incurred and reasonable in amount”, with any doubt resolved in favour of the receiving party. Rule 198 requires standard costs to be proportionate as well as reasonable, with doubt resolved in favour of the paying party. Proportionality and the benefit of the doubt are what move between them.

The threshold for indemnity costs is conduct on the paying party’s side “which deserves a mark of disapproval; unreasonableness of a high degree may be sufficient” — Afkar Capital Ltd v Saifallah Fikry, applying Ghafoor v Cliff.

3. Why the claimant's conduct crossed the line

The Court had already criticised how the case was run. The legal bases for the claims were never articulated with precision, leaving counsel to engage in what the judge called “shadow boxing”. A claimant must identify the precise legal rationale for each cause of action and the facts which, if proved, would establish its elements. Instead the claimant argued in the language of general injustice.

Adding the attempt to stretch negligence beyond its limits, and a pre-hearing offer that had been refused, the Court found the claims against the arm’s-length defendants deserving of a costs sanction and awarded them on the indemnity basis.

4. One set of costs — and why one defendant fared differently

Two points of practical structure:

  • Jointly represented co-defendants get one set of costs. Our client and its co-defendant were at arm’s length from the other parties, faced different claims, and shared one counsel — so they recovered a single set, assessed as one six-figure sum inclusive of court fees.
  • Connection to a live claim invites a discount. The third defendant was the holding company of a defendant whose claim continues. Because duplication of effort was likely, the Court ordered standard-basis costs and applied a 25% deduction, arriving at a materially smaller figure.

Practical takeaways

  • Plead the precise legal rationale and the facts that would establish each element. Vagueness is not neutral — it can cost you indemnity costs.
  • Arguing “injustice” rather than analysing the cause of action is exactly the conduct that attracts a costs sanction.
  • Make a well-judged pre-hearing offer; a refused reasonable offer strengthens an indemnity application.
  • Co-defendants sharing counsel should expect one set of costs — structure representation with that in mind.
  • Where a related party stays in the proceedings, expect a duplication discount rather than the full claim.

Sources & citations

  • Judgment: ADGMCFI-2025-283 (costs following summary judgment reported at [2026] ADGMCFI 0005) (ADGM Court of First Instance — Real Property Division). Costs order of 15 April 2026 following the summary judgment given on 4 February 2026 in the same proceedings, reported at [2026] ADGMCFI 0005. See the ADGM Courts judgments database. See the ADGM Courts judgments database.

Rules & practice directions cited


This case note is for general information only and does not constitute legal advice. For advice on an ADGM debt-recovery, enforcement or set-aside matter, please contact us. Last updated: 15 April 2026.

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Frequently asked questions

What is the test for indemnity costs in the ADGM?

Under r.199, the Court looks for conduct by the paying party deserving 'a mark of disapproval'; unreasonableness of a high degree may suffice — Afkar Capital Ltd v Saifallah Fikry [2018] ADGMCFI 0002, applying Ghafoor v Cliff [2006] EWHC 825 (Ch).

How do indemnity and standard costs differ?

Indemnity costs (r.199) must be reasonably incurred and reasonable in amount, with doubt resolved in favour of the receiving party. Standard costs (r.198) must also be proportionate to the matters in issue, with doubt resolved in favour of the paying party.

Can poor pleading lead to indemnity costs?

Yes. The Court criticised a claimant who never articulated the precise legal basis of its claims, leaving opponents 'shadow boxing', and who argued general injustice rather than analysing the causes of action. That conduct, with an over-stretched negligence claim and a refused pre-hearing offer, justified indemnity costs.

Do jointly represented defendants each get their own costs?

No. Co-defendants who share one counsel are entitled to a single set of costs. Here two arm's-length defendants sharing counsel recovered a single six-figure set of costs inclusive of court fees.

Why did one defendant get less?

It was the holding company of a defendant whose claim remains live, so duplication of work was likely. The Court awarded costs on the standard basis and applied a 25% deduction.