First-tier Tribunal Rules in favour of Park Owners on Insurance Compliance

OUTCOME: Allowed

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FIRST TIER TRIBUNAL [NAME] (RESIDENTIAL PROPERTY)

Case Reference

: CAM/00KB/PHC/2025/0013

[NAME]

: [COMPANY], [ADDRESS] [POSTCODE]

[NAME] Home Address : [ADDRESS], [COMPANY], [ADDRESS] [POSTCODE]

Applicant ([NAME] and Operators)

: The [APPELLANT]

Respondents ([NAME])

: Ms [NAME] & Mr [NAME] of [NAME] : To determine questions arising under the Mobile Homes Act 1983 or a Statement to which it applies under section 4 Mobile Homes Act 1983 - in particular: To determine whether there has been a breach of the express or implied terms of the Applicant’s Statement with the Respondents

Tribunal

: Judge JR Morris

Date of [NAME] : 7 May 2025 Date of [NAME] : 28 July 2025 Date of Decision : 10 October 2025

________________________________

DECISION _________________________________

© CROWN COPYRIGHT 2025

Decision

1. The Tribunal therefore determines that the Respondents are in breach of paragraph 3 (q) of Part IV of the Express Terms of the Written Statement of Agreement.

2. The Tribunal makes a direction under section 231A of the Housing Act 2004 that a reasonable time for the Respondents to remedy the breach is by 3 November 2025.

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3. The Tribunal makes an order on its own initiative for the Respondents to reimburse the Applicant’s [NAME] pursuant to Rule 13 (2) and (3) of The Tribunal Procedure (First-tier Tribunal) ([NAME]) Rules 2013 payable within 28 days after the Tribunal sends written reasons for the decision to the parties.

Reasons

Introduction

4. An [NAME] dated 7 May 2025 was made by the Applicant for a determination of a question arising under the Mobile Homes Act 1983 or the Written Statement to which it relates under section 4 of the Mobile Homes Act 1983 as amended, as follows:

5. The Applicant sought

1) a determination that the Respondents are in breach of part IV of the Express Terms of the Agreement under section 3 (q) which states:

“To insure and keep insured the mobile home with a member of the British Insurance Association against loss or damage by fire and liability to third parties and such other risks the owner may from time to time reasonably require and to produce to the owner upon request the policy of insurance and such other evidence as the owner may reasonably require that the policy is valid.”

2) a direction under section 231A of the Housing Act 2004 that the Respondents be required to remedy the alleged breach within a reasonable period and suggested 28 days.

6. [NAME] were issued on 28 July 2025 under which the Applicant was required to send a bundle of relevant documents to the Tribunal and the Respondents by 26 August 2025. The Respondents in return were required to send a bundle of relevant documents to the Tribunal and the Applicant by 8 September 2025.

7. The Applicant complied with [NAME]. The Respondents did not make any reply to the [NAME] or the Applicant’s statement of case or documents in support.

8. The [NAME] also stated that the [NAME] would be determined without a hearing based on the papers produced by the parties in their bundles unless any party requested a hearing by 1 September 2025. No request was received.

9. The [NAME] added that if no hearing was requested the matter would be determined on or after 29 September 2025. As no hearing was requested the matter is hereby determined based on the documents and written representations received.

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The Law

10. The relevant sections of the legislation are set out in Appendix 2.

Evidence and Submissions

11. The Applicant provided a written statement in the form of a witness statement by Mr [APPELLANT], the Applicant’s Operations Manager together with supporting documents. No statement, evidence or submissions were provided by the Respondents.

Applicant’s Case

12. In accordance with the [NAME] the Applicant provided a copy of the Written Statement of Agreement for the occupation of the pitch by the Respondents. The Agreement which commenced on 1 September 1982 was originally between the Applicant and the Respondents’ predecessors, Mr [APPELLANT] and Mrs [NAME], who assigned the Agreement to the Respondents on 2 December 2021.

13. The Applicant identified the relevant term of which it was believed the Respondents are in breach as being part IV of the Express Terms of the Agreement under section 3 (q) which states:

14. The Applicant also provided a copy of the [NAME] and [NAME].

15. The written statement of case provided by the Applicant in the form of a witness statement and documents by Mr [APPELLANT] is summarised as follows.

16. The Applicant explained the reasons for the need to insure saying that as part of the terms of the Respondents’ contract, there is a requirement to insure the [NAME] home. This requirement is to not only protect the Respondent homeowners against fire or natural disasters, but to also protect other homeowners in the vicinity. As responsible [NAME] owners and [NAME] operators we expect our residents to be compliant within the terms of the Agreement.

17. The Applicant said in September 2024 the [NAME] management team requested via letter dated 12 September 2024 that the Respondents update their insurance information with an up to date and valid insurance policy in accordance with the terms of the Agreement. A copy of the letter was provided which stated:

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“[NAME] has previously asked you for your insurance details for your home and you have yet to supply the information.

You should be aware that one of the legal obligations under the Mobile Homes Act Agreement, which ensures your right to [NAME] your home on the [NAME] is to: [Express Term 3 (q) was quoted]

We are sorry that you have chosen not to answer our enquiry and we are therefore concerned that your mobile home may not be insured. Within 14 days we ask you to produce proof that your home is currently insured to prevent the matter being treated as an agreement breach which may lead to it being referred to tribunal.”

18. The Respondents did not acknowledge or respond to the letter.

19. The Applicant said it wrote further to the Respondents on 29 October 2024 and within the letter advised the Respondents that under the terms of the Mobile Homes Act Agreement, the Respondents are required to keep the mobile home insured and upon request from the [NAME], provide evidence that the [NAME] home has a valid insurance policy. The Respondents were asked to provide the relevant information within 7 days. A copy of the letter was provided which stated:

“We are writing to you regarding previous letters from both [NAME] and Head Office and we are disappointed to note that no information regarding your home insurance has been supplied as requested.

We would like to remind you again that it is a term under the Mobile Homes Act Agreement that you insure and keep the mobile home insured and to produce to the [NAME] upon request the policy of the insurance and such evidence that it is valid.

Therefore, to avoid any further action on this matter, we politely request that you supply the above information within 7 days of this letter, and we thank you for your co-operation.”

20. The Respondents did not acknowledge or respond to the letter.

21. The Applicant said on not [NAME] a copy of the policy it sent a “Notice of Breach” letter to the Respondents on 20 November 2024 outlining the contravention of not providing a valid home insurance upon request. A period of 21 days was given for the contravention to be resolved. The Applicant also took the opportunity to advise the Respondents to seek available independent legal advice and included the relevant information within the letter. A copy of the letter was provided. At the time the Applicant believed that the Respondents additionally may be in breach of a [NAME] and the letter referred to this. Sections of the letter that refer to that matter are omitted as not being relevant to this [NAME]. The letter was headed and the relevant sections stated:

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“…

In accordance with the Terms of the Agreement, upon request for evidence that a [NAME] home has a valid insurance the [NAME] is required to provide the relevant [NAME] home insurance to the [NAME]. Currently, despite our requests to provide the relevant evidence that the [NAME] home is insured, this has not been forthcoming.

In accordance with the Written Statement under Mobile homes Act 1983 Amendment and section 3(q) of part IV of the Express Terms of the Agreement, which states [Express Term 3 (q) was quoted] …

To date we have unfortunately, not yet received a response nor an acknowledgement to any of our correspondence to you regarding this breach The [COMPANY] believe that a reasonable period has been given for the breach of the additional vehicle to have been removed from the [NAME], and the [NAME] home insurance to have been provided accordingly.

We cannot permit for these breaches to remain indefinitely and therefore, we require the following to remedy the said breaches.

A valid [NAME] home insurance policy is supplied to the [NAME] office providing evidence, that your home is insured in accordance with the Terms of the Agreement.

The [COMPANY], require that you remedy this breach within a reasonable time. In this case, we suggest a reasonable period is 21 days, from the date of this letter, with the date being 11 December 2024.

If the breach is not remedied within this period we will unfortunately, have no alternative, other than to make an [NAME] to the First-Tier Tribunal ([NAME]) Residential Property, and seek resolution that the said breaches are remedied.

We would kindly ask that you notify us within 7 days from the date of this letter of your intentions to remedy the said breaches of the [NAME] and the Terms of the Agreement.

Legal Advice

You may wish to consider taking independent legal advice. Advice is available from a solicitor or other suitably qualified professionals. Solicitors and suitable legal professionals may be sourced by telephoning The Law Society on [PHONE] (www.lawsocoety.org). Alternatively, free independent advice may be available from the following organisations. The Leasehold Advisory Service [PHONE] Citizens Advice ( www.citizens advice.org.uk) Community Legal Advice: [PHONE] (Mwww.clsdirect.org.uk)”

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22. The Respondents replied via email dated 20 December 2024, informing the Applicant that their insurance did not expire until February 2025 and claimed that proof would be provided once the Respondents was in receipt. A copy of the email was provided which stated:

Subject: 2 cars

To whom this concerns

Ref to the Letter received today via post. nothing previous by hand. The car is currently up for sale and should be gone by the new year. And the insurance doesn't expire until February 2025. Proof will be sent once received by myself.

23. The Applicant said that after this communication a “Letter Before Action” was issued to the Respondents dated 18 March 2025, advising that the Applicant was still not in receipt of the required [NAME] home insurance. The Contravention of the terms of the Agreement were further outlined to the Respondent and the Applicant advised that if the contravention was not addressed accordingly, the Applicant would have no alternative but to seek the assistance of the First-tier Tribunal ([NAME]) Residential Property for a resolve to the contravention. The Respondents were asked to provide the relevant information within 7 days. A copy of the letter was provided which stated:

“We previously wrote to you regarding home insurance for your [NAME] home and in accordance with the terms of your Agreement you are obligated to provide proof that your [NAME] home is insured in accordance with the terms of your Agreement.

As per your email dated 20th December 2024, you informed [COMPANY] that you would provide your insurance details for the period of 2024 to 2025 unfortunately, to date this is yet to be forthcoming. We are further concerned that from your previous correspondence which informed us that your home insurance expired at the end of February 2025, you have failed to produce the current years proof of insurance.

[As in previous correspondence reference was made to 3(q) of part IV of the Express Terms of the Agreement]

In accordance with the terms of the Agreement, upon request for evidence that a [NAME] home has a valid insurance the [NAME] is required to provide the relevant information.

As responsible [NAME] and Operators of [COMPANY], you need to have a specialist policy to insure your [NAME] home. We therefore, ask that you provide the required [NAME] home insurance information for the last year and the current year to show that you comply.

Please provide the requested information within 7 days from the date of this letter to our [NAME] office.

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We must take this opportunity to advise that we have previously requested this information from you to ensure that not only your own home is protected, but also that the neighbouring homes in the vicinity are protected.

If we are unable to address this contravention with you accordingly, then we will have no alternative but to seek the assistance of a First-Tier Tribunal ([NAME]) Residential Property for a resolve.

[As in previous correspondence reference was made to Legal Advice]

24. The Applicant said that the Respondents did not acknowledge or respond to the letter.

25. Having had no response the Applicant issued a “Notice of Breach” letter dated 1 April 2025 outlining the breach of the Agreement and advising the Respondents that the Applicant believed that a sufficient period had been given for the required information to have been provided. A further 14 days was given for the Respondents to provide the required insurance information and therefore to be compliant within the terms if the Agreement. A copy of the letter was provided which was in like form to that dated 20 November 2024 except it only referred to the issue of providing an insurance policy and made no mention of the Respondents believed breach of the [NAME]. The date for compliance was 15 April 2025.

26. The Applicant said that the Respondents did not acknowledge or respond to the letter.

27. The Applicant sent another “Notice of Breach” letter on 16 April 2025. A copy of the letter was provided which a reference to the Applicant’s belief that the Respondents were also in breach of a [NAME] and was in the same form as the letter dated 20 November 2024, the relevant parts of which have already been quoted. The letter gave a further date for compliance of 23 April 2025.

28. The Respondents did not acknowledge nor respond to the letter.

29. The Applicant submitted that it required the information to be provided to ensure that all residents on the [NAME] are safe and protected, it is a requirement of the Agreement with which the Respondents are obliged to comply and that by failing to provide a certificate of insurance they are in breach of the Agreement. The Applicant added that it found it extremely difficult to resolve this breach without coming to the tribunal as there has been minimal response from the Respondents.

Respondents’ Case

30. The Respondents did not submit any written evidence or make written submissions.

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Decision

31. The Tribunal considered the evidence and submissions of the Applicant none having been received from the Respondents.

32. The Tribunal found that paragraph 3(q) of Part VI, the Express Terms, of the Written Statement of Agreement required that the Respondents were required to insure their home “against loss or damage by fire and liability to third parties and such other risks the owner may from time to time reasonably require and to produce to the owner upon request the policy of insurance and such other evidence as the owner may reasonably require that the policy is valid.”

33. The requirement is in two parts, firstly a [NAME] must obtain insurance for the home and secondly, on request, a copy of the policy must be provided to the [NAME]. Although it could not be proved that the Respondents were in breach of the first part of the term, that they had not insured their home, nevertheless it could be shown that they were in breach of the second part, which is to provide proof that the home is insured by producing the policy or similar evidence.

34. The Tribunal found that the Applicant had requested production of the policy of insurance or other evidence to show that the Respondents’ home was insured. A formal letter requesting production had been sent to the Respondents on 12 September 2024 and a further formal request had been sent on 29 October 2024 both without result. A Notice of Breach letter was sent on 20 November 2024 which included a reference to a breach of the [NAME] which are not part of these proceedings, with a note advising the Respondents to take legal advice. The Respondents replied on 20 December 2024 referring to the breach of [NAME] which related to the parking of cars and states that “the insurance does not expire until February 2025”. The Tribunal wondered whether the Respondents were referring to the car insurance because when the home insurance expires is irrelevant to the request for a copy of the policy or similar evidence. In any event the Respondents reply indicates that they had received the Applicant’s letters and so were aware of the demand.

35. The Tribunal found that the Applicant had assumed that the Respondents had been referring to the home insurance and so expected a copy of the new policy following the expiry in February. As this had not been received a “Letter Before Action” had been sent on 18 March 2024. As no response was received the Applicant sent two further “Notice of Breach” letters on 1 and 16 April 2025 with a view to avoiding the expense of a tribunal [NAME], to no effect.

36. The insuring of a [NAME] home is not a trifling matter and the Tribunal agrees with the Applicant that a [NAME] is under an obligation to try and ensure that homes are insured by requesting and obtaining the relevant evidence. The Tribunal is satisfied that the Respondents have received the letters referred to which not only make the demand clear but also explain the necessity of obtaining insurance. The Tribunal found that the Respondents have had

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sufficient opportunity to obtain insurance, if they did not already have it and to provide evidence of insurance.

37. If there were a case to present other than to produce the evidence requested the Respondents have had opportunity to obtain legal advice (which was prompted in the Applicant’s letters) and present evidence and make submissions through this [NAME] procedure.

38. Having made its findings, the Tribunal made its determination as follows:

39. Firstly, the Tribunal considered whether the Respondents were in breach of the Terms of the Agreement as per the Written Statement under Mobile Home Act 1983 Amendment and Part IV of the Express Terms of the Agreement under paragraph 3 (q) which states:

40. The Tribunal found from the evidence adduced by the Applicant that the Respondents are in breach of the second part of paragraph 3 (q) of Part IV of the Express Terms of the Written Statement of Agreement in that they have failed “to produce to the owner upon request the policy of insurance and such other evidence as the owner may reasonably require that the policy is valid.”

41. Secondly the Tribunal considered a reasonable time in which the breach must be remedied. In doing so the Tribunal considered: • The seriousness of the consequences of the breach in that the [NAME] may apply to the County Court for the Respondents’ Written Statement to be terminated forthwith under Paragraph 4 of the Written Agreement which, if granted, will mean they would lose the right to their pitch. • That the breach could be relatively easily remedied by the Respondents in obtaining a policy of insurance as there are several providers who can be contacted by telephone or through the internet. In setting the time for compliance the Tribunal makes an allowance for obtaining a hard copy of a certificate of insurance, if the Respondents are not already in possession of evidence of insurance.

42. The Tribunal therefore determines that the Respondents are in breach of paragraph 3 (q) of Part IV of the Express Terms of the Written Statement of Agreement.

43. The Tribunal makes a direction under section 231A of the Housing Act 2004 that a reasonable time for the Respondents to remedy the breach is by 3 November 2025.

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44. The Tribunal makes an order on its own initiative for the Respondents to reimburse the Applicant’s [NAME] pursuant to Rule 13 (2) and (3) of The Tribunal Procedure (First-tier Tribunal) ([NAME]) Rules 2013 payable within 28 days after the Tribunal sends written reasons for the decision to the parties.

Judge JR Morris

APPENDIX 1 - RIGHTS OF APPEAL

1. If a party wishes to appeal the decision to the Upper Tribunal (Lands Chamber) then a written [NAME] for permission must be made to the First-tier Tribunal at the [NAME] which has been dealing with the case.

2. The [NAME] for permission to appeal must arrive at the [NAME] within 28 days after the Tribunal sends written reasons for the decision to the [NAME].

3. If the [NAME] is not made within the 28-day time limit, such [NAME] must include a request for an extension of time and the reason for not complying with the 28-day time limit; the Tribunal will then look at such reason(s) and decide whether to allow the [NAME] for permission to appeal to proceed despite not being within the time limit.

4. The [NAME] for permission to appeal must identify the decision of the Tribunal to which it relates (i.e., give the date, the property and the case number), state the grounds of appeal, and state the result the party [NAME] the [NAME] is seeking.

APPENDIX 2 – THE LAW

1. Section 4 of the Mobile Homes Act 1983 (as amended)

(1) In relation to a protected [NAME] in England, a tribunal has jurisdiction – (a) to determine any question arising under this Act or any Statement to which it applies, and (b) to entertain any proceedings brought under this Act or any such Statement subject to subsection (2) to (6).

(2) Subsection (1) applies in relation to a question irrespective of anything contained in an arbitration Statement, which has been entered into before that question arose.

(3) In relation to a protected [NAME] in England, the court has jurisdiction— (a) to determine any question arising by virtue of paragraph 4, 5 or 5A(2)(b) of Chapter 2, or paragraph 4, 5 or 6(1)(b) of Chapter 4, of Part 1 of Schedule 1 (termination by owner) under this Act or any Statement to which it applies; and (b) to entertain any proceedings so arising brought under this Act or any such Statement,

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subject to subsections (4) to (6).

(4) Subsection (5) applies if the [NAME] have entered into an arbitration Statement before the question mentioned in subsection (3)(a) arises and the Statement applies to that question.

(5) A tribunal has jurisdiction to determine the question and entertain any proceedings arising instead of the court.

(6) Subsection (5) applies irrespective of anything contained in the arbitration Statement mentioned in subsection (4).

2. Section 231A of the Housing Act 2004 provides:

Additional Powers of First-tier Tribunal and Upper Tribunal (1) The First-tier Tribunal and Upper Tribunal exercising any jurisdiction conferred by or under the Caravan Sites and Control of Development Act 1960, the Mobile Homes Act 1983, the Housing Act 1985 or this Act has, in addition to any specific powers exercisable by them in exercising that jurisdiction, the general power mentioned in subsection (2). (2) The tribunal’s general power is a power to give such [NAME] as the tribunal considers necessary or desirable for securing the just, expeditious and economical disposal of the proceedings or any issue in or in connection with them. (3) When exercising jurisdiction under this Act, the [NAME] which may be given by the tribunal under its general power include (where appropriate)— (a) [NAME] requiring a licence to be granted under Part 2 or 3 of this Act; (b) [NAME] requiring any licence so granted to contain such terms as are specified in the [NAME]; (c) [NAME] requiring any order made under Part 4 of this Act to contain such terms as are so specified; (d) [NAME] that any building or part of a building so specified is to be treated as if an HMO declaration had been served in respect of it on such date as is so specified (and such a direction is to be an excluded decision for the purposes of section 11(1) and 13(1) of the Tribunals, Courts and Enforcement Act 2007); (e) [NAME] requiring the payment of money by one party to the proceedings to another by way of compensation, damages or otherwise. (3A) … (4) When exercising jurisdiction under the Mobile Homes Act 1983, the [NAME] which may be given by the tribunal under its general power include (where appropriate)— (a) [NAME] requiring the payment of money by one party to the proceedings to another by way of compensation, damages or otherwise; (b) [NAME] requiring the arrears of pitch fees or the recovery of overpayments of pitch fees to be paid in such manner and by such date as may be specified in the [NAME];

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(c) [NAME] requiring cleaning, repairs, restoration, re-positioning or other works to be carried out in connection with a mobile home, pitch or protected [NAME] in such manner as may be specified in the [NAME]; (d) [NAME] requiring the establishment, provision or maintenance of any service or amenity in connection with a mobile home, pitch or protected [NAME] in such manner as may be specified in the [NAME].

3. Schedule 1 Part 1 Chapter 2 of the Mobile Homes Act 1983

Termination by owner

4. The owner shall be entitled to terminate the agreement forthwith, if on the [NAME] of the owner, the appropriate judicial body (County Court)— (a) is satisfied that the [NAME] has breached a term of the agreement and, after service of a notice to remedy the breach, has not complied with the notice within a reasonable time; and (b) considers it reasonable for the agreement to be terminated.

5. The owner shall be entitled to terminate the agreement forthwith if, on the [NAME] of the owner, the appropriate judicial body— (a) is satisfied that the [NAME] is not occupying the mobile home as his only or main residence; and (b) considers it reasonable for the agreement to be terminated.

5A. (1) This paragraph applies in relation to a protected [NAME] in England.

(2) The owner is entitled to terminate the agreement forthwith if— (a) on the [NAME] of the owner, a tribunal has determined that, having regard to its condition, the mobile home is having a detrimental effect on the amenity of the [NAME]; and (b) then, on the [NAME] of the owner, the appropriate judicial body, having regard to the tribunal’s determination and to any other circumstances, considers it reasonable for the agreement to be terminated.

(3) Sub-paragraphs (4) and (5) apply if, on an [NAME] to the tribunal under sub-paragraph (2)(a)— (a) the tribunal considers that, having regard to the present condition of the mobile home, it is having a detrimental effect on the amenity of the [NAME], but (b) it also considers that it would be reasonably practicable for particular repairs to be carried out on the mobile home that would result in the mobile home not having that detrimental effect, and (c) the [NAME] indicates to the tribunal that the [NAME] intends to carry out those repairs.

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(4) In such a case, the tribunal may make an interim order— (a) specifying the repairs that must be carried out and the time within which they must be carried out; and (b) adjourning the proceedings on the [NAME] for such period specified in the interim order as the tribunal considers reasonable to enable the repairs to be carried out.

(5) If the tribunal makes an interim order under sub-paragraph (4), it must not make a determination under sub-paragraph (2) (a) unless it is satisfied that the specified period has expired without the repairs having been carried out.

4. The Tribunal Procedure (First-tier Tribunal) ([NAME]) Rules 2013

Orders for costs, reimbursement of fees and interest on costs

13. (1) The Tribunal may make an order in respect of costs only— (a) under section 29(4) of the 2007 Act (wasted costs) and the costs incurred in applying for such costs; (b) if a person has acted unreasonably in bringing, defending or conducting proceedings in— (i) an agricultural land and drainage case, (ii) a residential property case, or (iii) a leasehold case; or (c) in a land registration case. (2) The Tribunal may make an order requiring a party to reimburse to any other party the whole or part of the amount of any fee paid by the other party which has not been remitted by the Lord Chancellor. (3) The Tribunal may make an order under this rule on an [NAME] or on its own initiative. (4) A person [NAME] an [NAME] for an order for costs— (a) must, unless the [NAME] is made orally at a hearing, send or deliver an [NAME] to the Tribunal and to the person against whom the order is sought to be made; and (b) may send or deliver together with the [NAME] a schedule of the costs claimed in sufficient detail to allow summary assessment of such costs by the Tribunal. (5) An [NAME] for an order for costs may be made at any time during the proceedings but must be made within 28 days after the date on which the Tribunal sends— (a) a decision notice recording the decision which finally disposes of all issues in the proceedings; or (b) notice of consent to a withdrawal under rule 22 (withdrawal) which ends the proceedings. (6) The Tribunal may not make an order for costs against a person (the “[NAME]”) without first giving that person an opportunity to make representations. (7) The amount of costs to be paid under an order under this rule may be determined by—

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(a) summary assessment by the Tribunal; (b) agreement of a specified sum by the [NAME] and the person entitled to receive the costs (the “[NAME]”); (c) detailed assessment of the whole or a specified part of the costs (including the costs of the assessment) incurred by the [NAME] by the Tribunal or, if it so directs, on an [NAME] to a county court; and such assessment is to be on the standard basis or, if specified in the costs order, on the indemnity basis. (8) The Civil Procedure Rules 1998(15), section 74 (interest on judgment debts, etc) of the County Courts Act 1984(16) and the County Court (Interest on Judgment Debts) Order 1991(17) shall apply, with necessary modifications, to a detailed assessment carried out under paragraph (7)(c) as if the proceedings in the Tribunal had been proceedings in a court to which the Civil Procedure Rules 1998 apply. (9) The Tribunal may order an amount to be paid on account before the costs or expenses are assessed.