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As per Andy Ellis's excellent article - https://www.lawgazette.co.uk/practice-points/fixed-costs-reform-on-the-right-track/5063186.article

"There remains a fundamental injustice. First, in preventing recovery of costs even when necessarily incurred (a fault that applies to every application of Jackson’s proportionality test). Second, in restricting what the Davids can recover with no limit on what the Goliaths may spend."