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Jeremy Warner

Year of Call: 2022
Email Address: [email protected]
Telephone: 020 7583 8055

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Clerk Details

  • Clerk Name: Jordon Gallifant
  • Clerk Telephone: 020 7583 8055
  • Clerk Email: [email protected]

Personal Injury

Jeremy has appeared in both the County Court and High Court and has been instructed in trials, CCMCs, pre-action disclosure applications, stage 3 hearings, strike out applications, relief from sanctions, and applications to resile across a variety of cases.

He has also made submissions on directions and budgeting in high value claims and has advocated before the Masters at the Royal Courts of Justice. During pupillage, he secured multiple costs orders in favour of his client.

  • Acting in a variety of personal injury related trials, including those involving allegations of fundamental dishonesty.
  • Multi-track applications and CCMCs, including a successful recent opposition to an application seeking to withdraw a pre-action admission in a £100,000 noise-induced hearing loss case.
  • Advising on liability and quantum in personal injury claims relating to spinal fractures, hip fractures, facial disfigurement, supraspinatus tears, and brachial plexus injuries.
  • Drafting Advice and skeleton arguments for multi-track personal injury claims, including complex injury cases relating to Ogden disability, Smith v Manchester awards, and the nuances of claims involving future losses.
  • Advising on liability and quantum, drafting skeleton arguments and injunctions in the cross-cut between education, personal injury law, and abuse.
  • Drafting pleadings in negligence, product liability, and cases under the Highways Act, Animals Act, employers’ liability, occupiers’ liability and road traffic accidents.
  • Striking out statements of case at Court for Road Traffic Accident cases.
  • Acting in credit hire litigation, where he has been often praised by the judiciary for his pragmatic approach.
  • Articles

    • Too Little, Too Late? Applications To Withdraw Pre-Action Admissions

      2nd Jul 2025

      Winding back the clock and withdrawing a pre-action admission is difficult. There is inevitably a tension between the finality of litigation and the interests of fairness. When a pre-action admission is made, the trajectory of a claim is set in motion. As the White Book commentary provides scant guidance on CPR 14.5, in this article I examine what happens when a defendant seeks to withdraw that admission, with particular focus on Somoye v North West Anglia NHS Foundation Trust [2023] EWHC 191 (KB) and the Court of Appeal’s guidance in Wood v Days Healthcare UK Limited [2017] EWCA Civ 2097.

      View Article

    • A clarification of the “relationship akin to employment” and the “sufficiently close connection” tests in grooming cases

      5th Sep 2023

      Michelle Marnham and future 3PB Pupil Jeremy Warner analyse MXX v A Secondary School [2023] EWCA Civ 996, a case concerned with the grooming of a minor, in which the Court of Appeal clarified that work experience can be a relationship akin to employment for the purpose of vicarious liability. The Court confirmed the difficulty to satisfy the “close connection” test, which requires for the tort and the employment of the tortfeasor to be “inextricably woven”.

      View Article
  • Recommendations

    “I was hugely impressed by Jeremy at the recent inquest. He was proactive, engaged and focussed, cutting to the heart of the key issues. His calm and thoughtful manner was a huge source of reassurance for the family during an incredibly difficult and emotional process. I look forward to instructing Jeremy again in the future”.

    “I did consider Jeremy’s assessment of the relevant issues to be spot on and it was clear that he had gone through the papers with a fine tooth comb and noted pertinent issues. I would be more than happy to instruct you again on matters and will confirm the same to members of my team for their own files.”

    “Jeremy clearly understood his brief well and had a good knowledge of the vagaries of credit hire and the specifics of this matter. Overall, this was a positive experience and a good outcome for the client, I would happily book him again for such work.”

    “Jeremy has been very attentive to the details of the case and notified us in good time of any queries he thought the court would raise. He won our case in Court and we would definitely book him in again.”

    “His communication prior to an up to the hearing was greatly appreciated and which resulted in a settlement moments before the hearing. I will not hesitate to instruct him again.”

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