3PB's specialist personal injury and clinical negligence barrister Eloise Turnnidge reviews the case of Aldred v Cham .
Eloise is a personal injury barrister with a busy practice representing both Claimants and Defendants. She appears in court most days - covering trials, CCMCs and interim applications - in addition to maintaining her paperwork and advisory practice.
Eloise frequently acts for Defendants, at trial and in the earlier stages of litigation, in claims involving allegations of fundamental dishonesty. She has persuaded the court to make findings of fundamental dishonesty, including findings of ‘phantom’ occupancy and staged or fabricated accidents, on a number of occasions. She has also secured a number of mid-trial drop hands offers. Her cross-examination has been described by the judiciary as “detailed and strong forensic examination” and she is known for pursuing matters “assiduously”.
Eloise’s multi-track work is predominantly Claimant based. She has assisted throughout the life of a number of cases and offered strategic advice accordingly, resulting in favourable settlements. Her Defendant practice also enables her to anticipate challenges and address potential issues at an early stage.
Eloise has a strong paperwork practice, advising and settling pleadings in matters worth over £100,000. She is adept at handling high value claims involving multi-disciplinary expert evidence, and has advised in both expert and client conferences. She is comfortable engaging with complex causation and quantum issues, as well as Ogden future loss calculations.
Eloise is developing her clinical negligence practice, including fatal accidents covering both the FAA 1976 and the LR(MP)A 1934. She has appeared in court and advised on many fatal claims worth over £100,000.
Eloise was recognised as a ‘Rising Star’ in the 2022 and 2023 editions of the Legal 500: Eloise is “excellent tactically with significant insight and experience to progress complex cases in fraught situations”, with an “excellent eye for detail” and “a real ability to grasp the key points of claim.”
Outside of work, Eloise enjoys snowboarding, salsa and running.
Eloise’s experience incorporates the following areas of law:
- Employers’ liability
- Occupiers’ liability
- Public liability
- Road traffic accidents
- Credit hire
- Holiday illness
- Accidents abroad
- Highways Act
Eloise Turnnidge accepts instructions for hearings and paperwork such as:
- Interim applications, including:
- Strike out and summary judgment
- Expert evidence
- Disclosure (including specific and non-party)
- Procedural (Part 20, service, set aside judgment)
- Limitation (section 33)
- Drafting pleadings and interim applications
- Advising on liability, causation, quantum and costs
Recent cases include:
S v S  - Eloise obtained the dismissal of claims brought against her client’s insured driver, where there were significant concerns regarding causation of injury, balanced with liability issues on the Defendant’s side, with the Claimant’s primary case on liability aligning with the insured driver’s account.
Q v U and P  - Eloise obtained a significantly reduced award in respect of a credit hire claim, persuading the judge to reduce the figure of approximately £12,000 to just £450.
N v S and H  - Eloise acted for the successful Second Defendant in a strike out application, with issues engaging the principles in Cameron v Hussain , defective service and other procedural issues. Eloise also assisted with the subsequent appeal, advising in respect of tactics and next steps, with the Claimant then abandoning his appeal.
B v H  - Eloise acted for the Claimant from the outset of proceedings in this liability-disputed, multi-track (>£100,000) public liability claim with disputed, multi-disciplinary expert evidence. Eloise advised in conference, settled pleadings including the schedule of loss, and attended hearings through to PTR, advising on tactics and assisting in obtaining a substantial settlement for the client.
P and P v O  - Eloise obtained settlement in terms that the Claimants do pay the Defendant’s costs, following her cross-examination of the Claimants and their subsequent drop hands offer.
R v I  - Eloise acted for the Claimant in this RTA matter, where the Claimant sustained head injuries and psychological disorders. Her loss of earnings claim was complicated by the Covid-19 pandemic and pre-existing symptoms, however Eloise’s advice led to a substantial settlement without the need to issue proceedings.
K v U  - Acting for the Defendant, Eloise obtained findings of fundamental dishonesty and phantom occupancy in this liability-disputed matter.
N and S v H  - Eloise obtained findings of fundamental dishonesty in both claims in this matter, in which the Claimants alleged injuries arising out of an RTA, despite a lack of witness evidence for the Defendants.
C v K  - Eloise secured a finding of fundamental dishonesty in this RTA matter in which the court accepted that the collision was caused by a ‘deliberate and calculated act of the Claimant’, with the judge also stating that she was unable to accept the Claimant had sustained any injury.
S v T  - In this remote trial in which the Claimant was only able to connect via audio, Eloise acted for the Defendant and persuaded the judge to make a finding of fundamental dishonesty. The judge accepted that the Claimant had fabricated the accident.
S v E  - In this claim worth approximately £50,000, arising out of an RTA for which liability was disputed, Eloise acted for the successful Defendant, securing dismissal of the claim on liability.
M v R  - In this RTA matter, Eloise acted for the Defendant and obtained a finding of fundamental dishonesty, with the judge finding with ‘no hesitation’ that an alleged RTA had not taken place. Eloise highlighted inconsistencies in bank statements, odometer readings and the Claimant’s accounts surrounding the alleged injuries.
S v R  - Eloise obtained a drop hands settlement in this credit hire matter, following her cross-examination of the Claimant at trial.
R v G  - Eloise acted for the Defendant in this RTA matter, securing a strike out on the basis of principles set out in Cameron v Hussain .
Supreme Court refuses permission to appeal in Aldred v Cham 18th Aug 2020
'Eloise is a skilled advocate and presents arguments and cases well in court and on paper. She is meticulous in her preparation and is always available to discuss tactics and prepare arguments well in advance of hearings.'
Legal 500 2024/ Personal Injury/ South Eastern Circuit/ Rising Stars
‘Eloise is a competent individual and absolute pleasure to work with. She prepares in good time and has an excellent eye for detail. Corresponding with her is very easy.’
‘a competent and strong advocate who never shies away from a tough cross-examination and confidently takes the lead in questioning’.
Legal 500 2023/Personal Injury/London Bar/Rising Star
‘Eloise has an excellent attention to detail and a real ability to grasp the key points of claim. She is always able to offer practical and pragmatic advice. She has an excellent manner with clients and is very good at explaining complex points which the client can easily understand.’
Eloise Turnnidge is ‘excellent tactically with significant insight and experience to progress complex cases in fraught situations’. Rising star Eloise Turnnidge garners praise for her ‘decisive and pragmatic approach’ and for being ‘well-prepared and running the best points of the case’.
Legal 500 2023/Personal Injury/South Eastern/Rising Star
‘She is very focused on the important issues in a case and is both pragmatic and sensible.’
Legal 500 2022/Personal Injury/South Eastern Circuit
“Eloise is a reasoned and robust advocate, arguing forcefully the issues and complexities in the case and often achieving great success. She is meticulous and persuasive in her written work and gives clear and sound advice on the strength of the arguments and prospects of success. She is very approachable and quick to respond with further advice or additional information as the case develops and is always thoroughly prepared to present the case at trial. Eloise is calm and confident in court and gets quickly to the issues, regularly achieving excellent results. She is highly regarded in the Counter-Fraud arena and a pleasure to work with. She comes highly recommended.”
Gareth Berry, Keoghs LLP
‘‘Eloise inspires confidence in all of her clients with clear and commercially focused advice. She possesses excellent client care skills, adding tremendous value with contributions over and above her attendances at Court, or when engaged in an advisory manner on complex cases.
Eloise is highly organised, technically strong & consistently secures excellent results for her clients.’’
James Power, Partner, Horwich Farrelly LLP
“Eloise is an extremely talented advocate with a wealth of knowledge, she has an eye for detail and commercial awareness and always approaches a case in a professional manner. Her achievements speak volumes about her ability.
I have previously instructed Eloise on a high value personal injury claim with a tight deadline, she proved how she will go ‘the extra mile’ for her clients by producing an extensive piece of advice which was clear, thorough and informative. Eloise works efficiently and diligently and is viewed as a very ‘safe pair of hands’.
It is always a pleasure to work with Eloise and I would thoroughly recommend her to anyone.”
Sophie Anderson, Kennedys LLP
“Eloise has represented my clients on a number of application hearings, trials and drafted numerous Defences following conferences with my client’s policyholders. I can highly recommend Eloise who always goes out of her way to assist including any questions or further discussions that I require. I always feel at ease discussing my matters with her as she is very personable. She is a very helpful and diligent individual. Eloise will pay attention to detail and will offer great advice.”
Samantha Murray, Keoghs LLP
"I have instructed Eloise on numerous motor claims where fundamental dishonesty is suspected. She has an excellent eye for detail and is thorough and hardworking. She has a very respectable balance between her professional and friendly side and is an absolute pleasure to work with. I would always recommend her to other colleagues."
Charlotte Moss, Keoghs LLP
"Eloise has covered a range of matters from hearings, conferences and applications on behalf of our clients. Conference calls with insured drivers were made easy by Eloise’s approachable and personable nature. Eloise has provided excellently drafted Court documents ranging from defences to skeleton arguments pre-trial. She has achieved excellent results at trial including obtaining a finding of fundamental dishonesty against a Claimant on more than one occasion. I would not hesitate to recommend Eloise for any work involving civil litigation.”
“I recently instructed Eloise to provide two Quantum Opinions. The Opinions were very thorough, and Eloise assisted with some detailed loss of earnings calculations. She provided the Opinions within a reasonable timescale and also at a reasonable cost. She was happy to answer questions for clarification. I will definitely use Eloise in the future.’’
Chartered Legal Executive