The appellant solicitor appealed an order directing the assessment of his accounts, arguing the application was barred by the two-year limitation period in the Limitations Act, 2002.
The respondent client had brought the application almost three years after paying the final account, citing poor health and an inability to manage her affairs as special circumstances.
The Court of Appeal dismissed the appeal, holding that section 20 of the Limitations Act preserves the 'special circumstances' exception set out in section 4 of the Solicitors Act, meaning there is no absolute time bar against applications for the assessment of lawyers' accounts.
Alternatively, the transitional provisions of the Limitations Act applied to preserve the former limitation period.
