Susan Jones practices across 3PB’s areas of expertise. Susan has experience in regulatory matters particularly licensing and inquests.
In 2015-2016 Susan undertook a secondment in an Inquest team at a large solicitors firm during which she appeared in inquests involving: prison deaths, deaths in care, hospital deaths including during cardiology and urology procedures, neonatal deaths, sudden unexpected death, article 2 and jury inquests.
Susan has recently:
- Appeared in an 8 day jury inquest arising out of a fatal jet ski collision
- Appeared in a 7 day jury inquest arising out of a death in HMP Pentonville
- Appeared in the High Court for the Respondent in an appeal against refusal to set aside a statutory demand
- Appeared for the Respondent in an appeal arising out of a stage 3 MOJ Low Value personal injury hearing
- Advised on, drafted the defence and successfully made legal submissions to strike out a commercial multi-track claim on the basis of pure economic loss
- Appeared for a Local Authority in an appeal pursuant to refusal to grant a licence under the Animal Boarding Establishment Act 1963.
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Susan has experience of appearing before a variety of public law and regulatory forums.
In 2016 Susan appeared for a Local Authority in a long running case involving an appeal against refusal to renew a license under the Animal Boarding Establishments Act 1963. The licence being necessary for carrying on a business of providing accommodation at premises, including a dwelling, for other peoples cats and dogs.
Susan is regularly instructed to appear in taxi licensing appeals and will consider acting on a direct access basis.
In 2016 Susan appeared for a local authority in a number of appeals against revocation of Hackney Carriage Licences with immediate effect under the Local Government (Miscellaneous Provisions) Act 1976, when drivers breached a Traffic Regulation Order by a pedestrianised areas.
In 2017 Susan represented a Licensing Authority in a taxi licensing appeal in which the license holder was accused and acquitted of rape. Upon learning of the allegation the Licensing Authority revoked the driver’s license with immediate effect in the interests of public safety. During the course of the licensing appeal, Susan highlighted the burden of proof depends on the nature of proceedings and the purpose of criminal and licensing proceedings are very different. Susan relied on a transcript of the complainant’s ABE interview, the driver’s PACE police interview and Crown Court Transcript when questioning the officer in the case and the driver. The driver’s appeal was refused.
Susan has appeared before a taxi and private hire licensing sub-committee on behalf of a taxi conglomerate for consideration of fitness of two directors to continue holding Private Hire Operator Licences. This involved issues of natural justice and responding to a report from the Head of Transportation Services.
Before the Traffic Commission, Susan represented four Lorry companies in a multi day, multi issue inquiry arising from five reports concerning professional competence, good repute, satisfaction of fundamental licensing requirements and financial standing. The case involved a history of receipt of a large number of PG9’s including some serious roadworthiness prohibitions. Concerns were raised relating to third party trailers, inadequately of checks, driver failings and issues surrounding nominated Transport Managers. The licences of each company had previously been suspended due to failure to provide evidence of appropriate financial standing. Susan ensured the financial suspension was lifted on the first day of the inquiry. Following the evidence and submissions, all parties received Formal Warnings.
Susan has represented Duty Premises Supervisors before licensing sub-commitees and appeared in review hearings and applications for extension of opening hours. She has also represented publicans in criminal sentencing hearings involving consideration of suspension of their personal licence under the Licensing Act 2003.
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Susan has experience conducting a variety of court hearings within this area, including:
- Insolvency and Bankruptcy
- Bankruptcy applications including following failed IVAs
- Disclosure applications from third parties under section 366 and 367 Insolvency Act
- Applications to set aside statutory demands.
- Protection of property orders on behalf of Trustees
In 2016 Susan appeared in the High Court for the Respondent in a hearing concerning contractual interpretation following the dismissal of an application to set aside a statutory demand for over £80,000. The issues turned on the true contractual interpretation of a clause setting out that, in the event that any contractual instalment of the loan was missed, the creditor could commence bankruptcy proceedings. This case involved consideration of the recent Supreme Court judgment of Arnold v Britton  UKSC 36 and in the High Court, Susan's submissions were accepted.
In 2017 Susan represented joint Trustees in Bankruptcy at a final hearing in which Trustees sought declarations that property, namely cattle and farm machinery vested in them. The Bankrupt raised that following the death of his father with whom he had traded in partnership, the cattle and farm machinery were his mother’s property. The life of these proceedings involved: preservation orders for cattle and farm machinery and delivery up orders attended by Susan and other members of Chambers. In addition to an ownership dispute the final hearing also considered capacity of the Bankrupt’s mother. The Court ordered the property vested in the Trustees entirely.
Susan has experience recovering professional fees involving Estate Agents and Veterinary surgeons.
Susan defended a veterinary practice in claim alleging negligent treatment of a dog’s skin condition and breach of contractual and duty of care for later refusing to carry out a procedure under general anaesthetic with a claim for loss of earnings. Susan explored in evidence the break down in trust and confidence between the vet and their client and what if any loss stemmed from the approach taken by the veterinary practice. The Judge accepted the position Susan presented on behalf of the veterinary practice and the Claim was dismissed.
Susan successfully argued quantum meruit in a dispute for mediation fees.
A client recovered the full cost of a new kitchen after a professional cleaning organisation was found negligent and in breach of implied contractual terms. Damage to the kitchen units was noticed days after steam cleaning was undertaken. Both parties instructed furniture experts, their reports dealt with delay in the appearance of damage and steam damage patterns and whether the damage could have been attributed to a kitchen kettle.
Energy & Utilities
Susan represented electrical subcontractors employed by a local authority, when the local authority joined them to an action in which it was alleged they had negligently connected the electrical supply of business to the supply network. Susan advised and drafted the pleadings. Susan asserted the initial claim for pure economic loss was misconceived. The pure economic loss defence was not raised by the first defendant. The matter was listed for half a day of legal argument before HHJ Luba QC. Susan made submissions in respect of pure economic loss principles and negligent misstatement. HHJ Luba QC was satisfied for the reasons Susan submitted that there was no legally recognisable claim.
Trading and Business Financing
Susan has appeared in a number of hearings involving reliance on guarantees and indemnities.
27th Apr 2017
Susan Jones relies on April 2017 Court of Appeal decision to defend a £49,000 costs application in its entirety. On 20th April 2017, in what is likely to be one of the first applications of the Court of Appeal decision in Peter Mills Dammerman v Lanyon Bowlder LLP (2017) Susan successfully appeared for a Defendant in a costs dispute following settlement of a small claim in favour of a Defendant's counterclaim for an offer made by the Claimant almost 3 years earlier.
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Susan accepts instructions in a wide range of personal injury matters and acts for Claimants and Defendants.
Susan regularly attends:
- Costs and Case Management Hearings (CCMCs)
- Interim applications, including relief from sanctions
- Trials involving liability, causation and quantum disputes
- Infant and protected party approval hearings for a wide range of injuries including fatal injuries
- Conciliation hearings
Susan has experience of personal injury claims concerning occupier’s liability, the Highway Act, food poisoning, accidents at work, road traffic accidents, sporting accidents and fatal injuries arising in a wide range of circumstances.
Susan has acted or is currently acting for Defendants in cases in which:
- Fundamental dishonesty is alleged, made out and qualified one-way costs shifting (QOCS) has been disapplied.
- Breach of duty is admitted but causation disputed based on Late Notification, in which following cross examination the Claimant did not make out their case.
- Following discontinuance Defendant costs are pursued based on fundamental dishonesty.
- Arguments have been raised regarding purported discontinuance and strike out has been sought in addition or as an alternative to fundamental dishonesty.
- After trial liability has been made out against one Defendant but not the Defendant Susan represented in which case Susan secured an enforceable Defendant costs order up to the extent of damages awarded.
- Only quantum is disputed but the Claimant has failed to better a Defendant Part 36 offer, with costs consequences.
- A quantum only dispute was allocated to the Fast Track, but Susan successfully argued the claim unreasonably left the Portal resulting in the Claimant being limited to Portal costs with significant cost savings for the Defendant.
Susan represented a Claimant at trial where the Claimant alleged, he burnt his hand while working for the Defendant when required to set fire to sawdust on the Defendants premises. The matter was defended on the basis that the Defendant never employed the Claimant (there was no contract of employment, no evidence of payments and the Claimant did not have a UK work permit) and in any event that the incident did not occur on his premises (there being no accident book entry, or any other record and the incident described was not something tolerated by the Defendant). Following a full day trial, the judge found for the Claimant and heard submissions on quantum for burn injuries.
Susan recently advised a local authority in respect of life long dental treatment required by a child following a liability admitted accident. On behalf of the Defendant Susan attended the approval and informed the Court that the settlement was fair, excluded double counting suggested in the Claimant’s schedule of loss and applied the correct discount rate.
Susan represented a child at an assessment of damages hearing, who sustaining deep facial laceration requiring surgery under general anaesthetic, leaving permanent scarring with a likelihood of further future treatment. The Claimant also suffered post traumatic anxiety that resolved.
Susan provides advice on quantum and attends infant and protected party approval hearings, including for dependents following fatal accidents. She has considered issue relating to hostile litigation friends and matters arising when Defendant's potentially lack capacity in areas of law outside the remit of personal injury.
Susan is happy to draft pleadings and advise on prospects and quantum.
Susan is a member of PIBA and attends their annual March conference.
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Susan has experience dealing with cases in which the determination of the cause of death are complex and involve the assessment of factual evidence and the opinions of a number of experts.
Susan has experience with inquests involving:
- Deaths in custody
- Care homes death
- Hospital deaths, including complications in cardiology and urology procedures and labour
- Emergency Services attendance
- Neonatal deaths
- Sudden Infant Death
- Sudden adult deaths
- Road Traffic Deaths
- Water related deaths
- Article 2 inquests
- Jury inquests
- Multi day inquests
Susan completed a 7-month secondment in the inquest team at Capsticks solicitors during which she prepared cases from receipt of initial instructions and appeared as the advocate at the inquest. Susan continues to build on this area of work.
- Baby D: Susan represented an NHS Trust in an inquest concerning a neonatal death with alleged antenatal and neonatal failings surrounding Haemolytic Disease of the New Born. Although the coroner was critical of care provided by the Trust, no causative failings were established.
- Susan represented a family in a two-day inquest following the death of a woman with placenta accrete who died post emergency caesarean section as a result of torrential haemorrhage. This inquest involved extensive obstetric evidence from clinicians, an independent obstetrics expert and a pathologist with an interest in maternal death. Evidence considered antenatal reviews, timing of the caesarean section, surgical entry and postoperative care. The coroner made neglect findings.
- Re LM-B: Susan appeared on behalf of a Trust providing psychiatric care to a patient who collapsed in the street. Prior to the inquest Susan drafted instructions and questions for a toxicology expert to advise on post mortem redistribution and other factors affecting post mortem blood concentrations of anti-psychic drugs and anti-depressant (clozapin and venflaxin), that according to the post mortem were present after death at toxic and fatal levels. At the inquest Susan questioned the pathologist and expert witness. The coroner returned a natural causes conclusion.Re CMcL: inquest into the death of a member of hospital staff arising out of a rare but recognised complication during an elective investigatory angiogram. Live evidence was heard from consultant pathologist, consultant cardiologist and registrar.
- Re JP: this inquest involving attendance by emergency services and delays at the scene whilst awaiting a bariatric ambulance. Questions were raised about the time taken for the ambulance service to transfer JP to hospital.
- Re AH: 7 day jury inquest into the death of a prisoner who received a drugs package into HMP Pentonville, on which he subsequently choked. This inquiry included investigation into prisoner restraint.
Care Home Deaths
- Re DB: 4 day inquest into the death of a dementia resident who whilst in care was struck in the face by another dementia resident, involving examination of medical records of a living person to determine if there were any missed opportunities to protect others. Susan advised on disclosure of the records of a living person who lacked capacity and made submissions to the coroner in respect of disclosure.
- Re NMcL: 5-day inquest into the death of an elderly care home resident suffering with dementia after falling from a chair and sustaining a fractured neck of femur. This matter went part heard at which point Susan succeed in getting her client’s status demoted to an interested person on the basis of “sufficient interest” only.
Local Authority Related Deaths
Susan has appeared for various Local Authorities in inquests concerning:
- Drowning on a beach, exploring adequacy of signage and personal rescue equipment and whether these were in accordance with Royal National Lifeboat Institute (RNLI) guidance.
- Death following a tree falling into a vehicle on the highway
- The death of a 3-week-old baby, considering co-sleeping and whether the actions of social services and other agencies were appropriate. In evidence Susan explored the rationale behind the approach taken by social services and the frequency of their interactions with other agencies. A conclusion of Sudden Unexpected Death in Infancy (co-sleeping) was returned and in respect of prevention of further death reports, the coroner indicated that the evidence clarified the multi-agency approach was appropriate and a PFD report was unnecessary.
- In an 8-day jury inquest in 2017 Susan represented a novice jet skier involved in a fatal collision resulting in the death of an experienced jet skier. The inquest involved complex factual and expert evidence, including expert evidence regarding water collision reconstruction and medical causation. The Coroner requested submissions on the appropriateness of leaving unlawful killing to the jury.
Susan has attended the following inquest seminars:
- 'The Coroner’s and Justice Act 2 years on'
- 'The Coroner’s Inquest some current dilemmas'
- His Honour Judge Mark Lucraft QC, Chief Coroner, address to the 2018 PIBA conference.
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Susan uses experience gained in her personal injury and inquest practice to assess claims in this area. Susan has advised Claimants and Defendants in deaths of adults and children arising from alleged clinical failures.
Susan has recently advised on lifelong dental injuries and is interested in developing a cosmetic and dental negligence practice.
In light of Montgomery v Lanarkshire Health Board  UKSC 11 Susan has advised in cases relating to adequacy or otherwise of information given to patients upon which they are to decide whether or not to undergo a particular type of treatment. Susan is currently involved in a class action in this respect.
“May I personally record my admiration of Susan Jones performance before Mrs Justice Lambert. I sat behind her as a solicitor with 25 years post qualification experience and witnessed a rising star. She stood her ground against Mrs Justice Lambert’s initially strident view that the judge below had reached a wrong decision on the facts and gently set out in a highly effective, forensic way how the judge’s opinion below should not be interfered with…...High Court Judges don’t mess around, neither did Susan" (Instructing solicitor in Susan Jones successfully opposition of High Court Appeal challenging both Procedural Matters and Findings of Fact)
“Speed and uptake was impressive to say the least, as was her energy and the commitment she made. Since this first encounter, we have sought to use her whenever possible. Having sat next to her I can say that she is an accomplished advocate with a compelling style of advocacy” (Partner, instructing and attending a 3 day hearing)
“Our client is very happy with the outcome and I would certainly not hesitate to use Miss Susan Jones in the future or recommend her to my colleagues”. (Solicitor)
“Thank you for your advice which is both thorough and lucid of its analysis of the case” (Associate Solicitor)
“Miss Jones was extremely helpful and professional. I do not see how we could have done any more to better present my case” (Lay Client)
- Queen’s University Belfast (LLB: First, Top in Year)
- City University Law School (Bar Professional Training Course: Outstanding)
- BPTC scholarship
- Sweet and Maxwell Prize - most distinguished student in LLB final examinations
- Queen’s University Belfast awards for:
- Jurisprudence and political economics
- Contract law
- Trademarks and unfair competition
Professional qualifications & appointments
- Western Circuit Area Bar Junior (Winchester)
- Direct/Public access qualified
- Personal Injury Bar Association
- Association of Regulatory & Disciplinary Lawyers
- British Association for Sport and Law (BASL)
- Bar Pro Bono Unit
Susan Jones is qualified to accept instructions directly from members of the public and professional clients under the Direct Public Access scheme.More Information
3PB's Susan Jones represents family in inquest over the death of a dock worker
Properly-enforced safety procedures would have prevented the death of a dock worker crushed by a container, an inquest jury has concluded. Mieczyslaw 'Mitch' Si...Read more
Personal Injury update published by 3PB
The Personal Injury team has published its latest update including the latest on the Commons amendments regarding the Civil Liability Bill as considered by the ...Read more
Susan Jones successfully opposes High Court Appeal challenging both Procedural Matters and Findings of Fact
Susan Jones successfully opposed High Court Appeal before Mrs Justice Lambert Arising out of a Public Trial, at which Susan acted for the Claimant at First inst...Read more