§ GUIDE · LATE CLAIMS

Past the deadline
is not always the end

Most people assume that once three years have gone, the door is shut. The judgments say otherwise more often than you would expect. In the seven cases here, six late claims were allowed to proceed, including one about a birth 32 years earlier. This page is about that discretion. If you want the rule itself, and how it works for children, capacity and deaths, read the three-year rule guide first.

Judgments read

7

Late claims allowed

6 of 7

Longest allowed

32 years

If you are in time

See the rule

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§ BEFORE YOU GO FURTHER

Before you assume you are out of time, check these

  • The clock usually starts when you first knew the injury was significant and that it might be linked to the treatment, which can be much later than the treatment itself.
  • Knowing that what happened was legally negligent is not the test. Knowing enough to start asking questions is.
  • A child has until their eighteenth birthday, then three years. Someone who lacks the mental capacity to bring a claim has no deadline at all.
  • After a death, the three years runs from the death or from when the family knew enough, and the inquest does not pause it.

Even when the deadline has passed, the court can disapply it if a fair trial is still possible. That is a real discretion, exercised in six of the seven judgments below, but never something to rely on.

§ 01

When the clock actually starts

The three years usually runs from the date you first had the knowledge the law requires: that the injury was significant, that it might be attributable to the treatment you are complaining about, and who the defendant is. Crucially, knowing whether that amounts to negligence in law is irrelevant. You do not need to know you have a claim; you need to know enough to look into it.

Shaw v Maguire shows how much later that can be. A skin sample taken in 2007 was reported as benign when it showed melanoma, which was only picked up in 2009, and the patient died in 2014. The court found the clock started in 2013, when the family learned the cancer was terminal.

The other side of that rule is constructive knowledge: you are treated as knowing what you could reasonably have found out, including with expert help. In Whiston the Court of Appeal held a man born in 1974 should have looked into the cause of his cerebral palsy years before he did.

§ 02

When a court forgives lateness

Where the deadline has passed, the court can still allow the claim if it is fair to do so. It weighs how long the delay was and why, whether the evidence is less reliable because of it, how the defendant behaved, and how promptly the claimant acted once they knew. In practice the question that decides it is whether a fair trial is still possible.

Whiston is the furthest example: allegations about a forceps delivery in September 1974, a claim issued in 2006, and the court satisfied it was still fair to let it run. Khairule, about a 1981 birth, was around three months late and allowed. Mossa v Wise was allowed even though the surgeon had died, because the records and expert evidence still permitted a fair trial. Aderounmu was years late and allowed, after the court tested and rejected an argument that a brain injury had left him unable to bring a claim.

§ 03

When it is genuinely too late

De Meza is the one that failed, and it shows where the line is. A man treated in the early 1980s sued in 2014 over a hormone condition that was never followed up. The Court of Appeal found he had known enough in 1983 and that a 28-year delay had destroyed the records that would have shown what actually happened. Without those records there could be no fair trial, so the claim was struck out as too late.

That is the pattern. Delay by itself is survivable. Delay that has destroyed the evidence is usually not, which is another reason to get the records early.

§ 04

If your solicitor missed the deadline

It happens, and it does not automatically leave you with nothing but a claim against them. In Leeson v Marsden the first claim was issued in time and thrown out because it was served a day late. The court allowed a second, out-of-time claim to proceed against the original defendants, because a fair trial was still possible and they had been ready to meet the case anyway.

§ 05

Children, capacity and deaths, in brief

A child's claim can be brought at any time before their eighteenth birthday and for three years after it, which is why so many birth injury cases are brought many years later. Someone who lacks the mental capacity to conduct a claim has no deadline while that continues.

After a death there are two claims, one for the estate and one for the dependants, and each runs three years from the death or from when the family knew enough. There is a trap: if the person who died was already out of time to bring their own claim, the dependency claim cannot be brought at all, and the discretion described on this page does not rescue it.

Our separate guide to the three-year rule sets all of this out in full, including what to do if you are close to the deadline and how the position differs in Scotland and Northern Ireland.

§ THE JUDGMENTS BEHIND THIS GUIDE

The seven judgments behind this guide.

Every one a published decision of the courts of England and Wales, linked to its source. Six late claims allowed, one refused.

Claimant succeeded

London Strategic Health Authority v Whiston

[2010] EWCA Civ 195·2010·Appeal decision

A man born in 1974 with cerebral palsy sued in 2006, saying he only learned in late 2005 that a junior doctor had persisted with forceps for around half an hour. The Court of Appeal held he should reasonably have looked into the cause much earlier, but still let the case go ahead.

Even a claim about a birth more than thirty years earlier can be allowed to run if a fair trial is still possible and the unfairness to the injured person outweighs the unfairness to the hospital. Being told at the time that an injury was just one of those things does not automatically stop the clock.

Claimant succeeded

Shaw v Maguire

[2023] EWHC 2155 (KB)·2023·Liability decided at trial

A skin sample taken in 2007 was reported as benign but in fact showed melanoma, which was only picked up in 2009 and caused the patient's death in 2014. His widow issued proceedings over five years late after her first solicitors let the case drift, and the court allowed the claim to proceed.

The clock can start later than the mistake itself, because it only runs once you know the injury is serious. Delay caused by former solicitors rather than by the claimant is far less likely to defeat a late claim, especially where the original slides and reports survive.

Claimant succeeded

Aderounmu v Colvin

[2021] EWHC 2293 (QB)·2021·Liability decided at trial

A young man saw his GP with slurred, very unclear speech and suffered a stroke four days later, but did not sue until 2017. The court found he had the mental capacity to bring a claim and had known enough by December 2010, yet allowed the late claim to go ahead.

Arguing that a brain injury left you unable to run a claim will be tested hard against your medical records and everyday dealings. Even so, a claim brought years late can survive if the records mean a fair trial is still possible.

Claimant succeeded

Mossa v Wise

[2017] EWHC 2608 (QB)·2017·Appeal decision

A woman who had vaginal tape surgery in 2007 sued in 2015, saying she was never properly told about the product or the alternatives. The surgeon had died by then, but the court allowed the late claim to proceed and the High Court refused to interfere.

A late claim can still go ahead even where the doctor has died, if independent records and expert evidence mean a fair trial is possible. The court weighs the harm to each side rather than applying the deadline mechanically.

Claimant succeeded

Khairule v North West Strategic Health Authority

[2008] EWHC 1537 (QB)·2008·Liability decided at trial

A man with severe cerebral palsy from his 1981 birth argued the caesarean should have happened much sooner. The court found he should have started asking questions by the end of 2002, which put the claim a few months out of time, but allowed it to proceed.

Someone disabled from birth is not expected to be as curious about the cause as someone injured in a one-off incident, so the clock may start later for them. A short overrun is likely to be forgiven where the records still allow a fair trial.

Claimant succeeded

Leeson v Marsden & Anor

[2008] EWHC 1011 (QB)·2008·Liability decided at trial

A woman with a spinal abscess was sent home from A&E and left with lasting spinal cord damage. Her first claim was issued in time but thrown out when her solicitors served it a day late, and this second, out-of-time claim was allowed to proceed.

If solicitors miss a court deadline, the law does not automatically leave the claimant with only a claim against them. The court can let a fresh, late claim run against the original defendants where a fair trial is still possible.

Claim failed

The Pennine Acute Hospitals NHS Trust v De Meza

[2017] EWCA Civ 1711·2017·Appeal decision

A man treated in the early 1980s sued in 2014, saying no one followed up his hormone condition until a new doctor restarted treatment in 2011. The Court of Appeal found he had known enough back in 1983 and that a 28-year delay had destroyed the records needed to defend the case.

Where very long delay means the records that would show what actually happened no longer exist, the court will usually hold the claimant to the deadline. Realising only years later that better treatment existed does not by itself restart the clock.

Browse the whole case library →

Contains information licensed under the Open Justice - Licence v2.0. Judgments from Find Case Law, The National Archives. Summaries are ours; amounts only where printed in the judgment.

§ QUESTIONS

Common questions

It happened more than three years ago. Is that the end of it?

Not necessarily. Six of the seven judgments here were late claims that were allowed to proceed. The questions are when you first knew enough to investigate, and whether a fair trial is still possible. It is worth asking rather than assuming.

I only found out recently that my care was poor.

Then the clock may have started recently. The test is when you knew the injury was significant and might be linked to the treatment, not when you learned it was legally negligent. Shaw v Maguire started the clock six years after the mistake.

My child was injured at birth years ago.

A child's claim can be brought at any time before they turn 18, and for three years after that. If they lack the capacity to bring a claim themselves, there is no deadline while that continues. The three-year rule guide covers this in full.

Why does delay matter so much?

Because of the records. De Meza failed after 28 years because the documents that would have shown what happened no longer existed. Where the records survive, as in Mossa v Wise, courts have allowed claims even after the doctor died.

My previous solicitor missed the deadline.

Leeson v Marsden shows that need not be fatal to the claim itself. A second, late claim was allowed against the original defendants. Take advice quickly, because the delay after you knew is one of the things the court weighs.

This guide is general information about the law in England and Wales, not legal advice about your case. ClaimGavel is run by Costart Projects Ltd on behalf of Tomlin & Partners, a specialist medical negligence firm regulated by the SRA. The free assessment on this page is an AI overview to show you roughly where you stand; a solicitor confirms the position in a free, no-obligation conversation.