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"For example I recall that even more pertinently, a Trainee used to command Scale D Costs under SCCO Guideline rates in 2010 which used to be £79.00 outside Central London / City."

Not so. Prior to the 2010 revision, grade Ds charged at £116 + Vat or £109 + Vat depending on where outside London they were.

To answer your question though, the guideline rates are just that. They are not tramlines. Their purpose is to guide (not confine) judges dealing with summary assessments. Costs in cases of this nature are not subject to summary assessment. Simply put, the guideline rates do not apply in cases of this nature.

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