The standard rate of interest on general damages for pain and suffering and loss of amenities in personal injury cases was fixed at 2% a year by the House of Lords in Birkett v Hayes [1982] 1 WLR 816; [1982] 2 All ER 70. This was confirmed as appropriate by the Court of Appeal in Lawrence v Chief Constable of Staffordshire [2000], The Times, 25 July.
The appropriate rate of interest for special damages is the rate, over the period for which the interest is awarded, which is payable on the court special account (the Special Account Rate or SAR). After seven years at 6% this rate was reduced to 3% a year on 1 February 2009, to 1.5% on 1 June 2009, and to 0.5% on 1 July 2009 where it has remained ever since. With the UK economy seemingly at risk of a triple-dip recession, it appears unlikely that the SAR will rise again before January 2014. Interest since June 1987 has been paid daily on a 1/365th basis, even in a leap year such as 2012.
In cases of continuing special damages, half the appropriate rate from the date of injury to the date of trial is awarded. In cases where special damages have ceased and are thus limited to a finite period, there are conflicting appeal court decisions as to whether the award should be half the appropriate rate from injury to trial (Dexter v Courtaulds [1984] 1 All ER 70), or the full special account rate from a date within the period to which the special damages are limited (Prokop v DHSS [1985] CLY 1037). Simple mathematics suggests interest should run at half SAR while the loss is continuing, and at full SAR thereafter. The House of Lords has confirmed that Department for Work and Pensions benefit should be disregarded when calculating interest on special damages (Wadey v Surrey County Council [2000] 1 WLR 820 (HL)).
Table 1 records the percentage total of SAR up to 1 January 2013 for each month since January 1992. In the left-hand column is shown the month from the first day of which interest is assumed to run. The right-hand column shows the percentage interest accumulated from the first day of each month to 1 January 2013.
Continued use can be made of this table by adding 1/365th of the annual SAR for each day beyond 1 January 2013 over which the interest is to be calculated. Table 2 records the accumulated number of days to the first day of each month as well as the additional interest to be added for that same period (on the basis that SAR remains at 0.5% throughout).
Interest for one full calendar month is currently 0.04%. The contribution to interest arising from part only of one month can be calculated to an acceptable level of accuracy by multiplying that figure by the number of the day in the month up to which interest is to be calculated and then dividing by 30.
Suppose that interest runs from 1 June 2011 to an estimated trial date on 17 June 2013. The interest to 1 January 2013 is 0.79% (table 1). The interest from 1 January 2013 to 1 June 2013 is 0.21% (table 2). The interest from 1 June 2013 to 17 June 2013 is 0.04% x 17/30 = 0.02%. The total interest from 1 June 2011 to 17 June 2013 is therefore 0.79% + 0.21% + 0.02% = 1.02%.
These tables should assist all those concerned with interest since 1992 to make calculations fluently. Although the tables’ primary application is to interest on special damages in personal injury cases, they are equally applicable to any other cases in which the special account is used in calculating interest. The tables are of particular use in long-running cases such as professional negligence cases, when historically high interest rates might have a significant impact on the value of the claim. The relevant rates since 1965 are conveniently set out in the White Book at note 709 and are reproduced in table 3 for completeness.
Andrew Morgan is a partner in the asbestos claims department at Field Fisher Waterhouse
Table 1 - rates of interest on special account since January 1992 (%) clear="all">
1992 | 1993 | 1994 | 1995 | 1996 | 1997 | 1998 | |
---|---|---|---|---|---|---|---|
January | 125.58 | 115.30 | 107.11 | 99.11 | 99.11 | 83.09 | 75.09 |
February | 124.71 | 114.13 | 106.43 | 98.43 | 90.43 | 82.41 | 74.41 |
March | 123.90 | 113.82 | 105.82 | 97.82 | 89.80 | 81.80 | 73.80 |
April | 123.03 | 113.14 | 105.14 | 97.14 | 89.12 | 81.12 | 73.12 |
May | 122.18 | 112.48 | 104.48 | 96.48 | 88.46 | 80.46 | 72.46 |
June | 121.31 | 111.80 | 103.80 | 95.80 | 87.78 | 79.78 | 71.78 |
July | 120.47 | 111.15 | 103.15 | 95.15 | 87.12 | 79.12 | 71.12 |
August | 119.60 | 110.47 | 102.47 | 94.47 | 86.44 | 78.44 | 70.44 |
September | 118.73 | 109.79 | 101.79 | 93.79 | 85.76 | 77.76 | 69.76 |
October | 117.89 | 109.13 | 101.13 | 93.13 | 85.11 | 77.11 | 69.11 |
November | 117.02 | 108.45 | 100.45 | 92.45 | 84.43 | 76.43 | 68.43 |
December | 116.17 | 107.79 | 99.79 | 91.79 | 83.77 | 75.77 | 67.77 |
1999 | 2000 | 2001 | 2002 | 2003 | 2004 | 2005 | |
---|---|---|---|---|---|---|---|
January | 67.09 | 59.51 | 52.49 | 45.49 | 39.41 | 33.41 | 27.39 |
February | 66.41 | 58.92 | 51.90 | 44.90 | 38.90 | 32.90 | 26.88 |
March | 65.80 | 58.36 | 51.36 | 44.44 | 38.44 | 32.42 | 26.42 |
April | 65.12 | 57.76 | 50.76 | 43.93 | 37.93 | 31.91 | 25.91 |
May | 64.46 | 57.19 | 50.19 | 43.43 | 37.43 | 31.42 | 25.42 |
June | 63.78 | 56.59 | 49.59 | 42.92 | 36.92 | 30.91 | 24.91 |
July | 63.12 | 56.02 | 49.02 | 42.43 | 36.43 | 30.41 | 24.41 |
August | 62.44 | 55.42 | 48.42 | 41.92 | 35.92 | 29.90 | 23.90 |
September | 61.85 | 54.83 | 47.83 | 41.41 | 35.41 | 29.39 | 23.39 |
October | 61.27 | 54.25 | 47.25 | 40.92 | 34.92 | 28.90 | 22.90 |
November | 60.68 | 53.66 | 46.66 | 40.41 | 34.41 | 28.39 | 22.39 |
December | 60.10 | 53.08 | 46.08 | 39.92 | 33.92 | 27.90 | 21.90 |
2006 | 2007 | 2008 | 2009 | 2010 | 2011 | 2012 | |
---|---|---|---|---|---|---|---|
January | 21.39 | 15.39 | 9.39 | 3.37 | 1.50 | 1.00 | 0.50 |
February | 20.88 | 14.88 | 8.88 | 2.86 | 1.46 | 0.96 | 0.46 |
March 20.42 14.42 8.40 2.63 1.42 0.92 0.42 April 19.91 13.91 7.89 2.38 1.38 0.88 0.38 May 19.42 13.42 7.40 2.13 1.34 0.84 0.34 June 18.91 12.91 6.89 1.88 1.29 0.79 0.29 July 0.29 12.41 6.40 1.75 1.25 0.75 0.25 August 17.90 11.90 5.89 1.71 1.21 0.71 0.21 September 17.39 11.39 5.38 1.67 1.17 0.67 0.17 October 16.90 10.90 4.88 1.63 1.13 0.63 0.13 November 16.39 10.39 4.38 1.58 1.08 0.58 0.08 December 15.90 9.90 3.88 1.54 1.04 0.54 0.04
Table two - accumulated total of days from 1 January 2012
To | Additional days | Additional interest |
---|---|---|
1 February 2013 | 31 | 0.04% |
1 March 2013 | 59 | 0.08% |
1 April 2013 | 90 | 0.12% |
1 May 2013 | 120 | 0.16% |
1 June 2013 | 151 | 0.21% |
1 July 2013 | 181 | 0.25% |
1 August 2013 | 212 | 0.29% |
1 September 2013 | 243 | 0.33% |
1 October 2013 | 273 | 0.37% |
1 November 2013 | 304 | 0.42% |
1 December 2013 | 334 | 0.46% |
1 January 2014 | 365 | 0.50% |
Interest runs presently at 0.04% pcm |
Table three - rates of interest on special account since 1965
From | ||
---|---|---|
1 October | 1965 | 5% |
1 September | 1966 | 5.5% |
1 March | 1968 | 6% |
1 March | 1969 | 6.5% |
1 March | 1970 | 7% |
1 April | 1971 | 7.5% |
1 March | 1973 | 8% |
1 March | 1974 | 9% |
1 February | 1977 | 10% |
1 March | 1979 | 12.5% |
1 January | 1980 | 15% |
1 January | 1981 | 12.5% |
1 December | 1981 | 15% |
1 March | 1982 | 14% |
1 July | 1982 | 13% |
1 April | 1983 | 12.5% |
1 April | 1984 | 12% |
1 August | 1986 | 11.5% |
1 January | 1987 | 12.25% |
1 April | 1987 | 11.75% |
1 November | 1987 | 11.25% |
1 December | 1987 | 11% |
1 May | 1988 | 9.5% |
1 August | 1988 | 11% |
1 November | 1988 | 12.25% |
1 January | 1989 | 13% |
1 November | 1989 | 14.25% |
1 April | 1991 | 12% |
1 October | 1991 | 10.25% |
1 February | 1993 | 8% |
1 August | 1999 | 7% |
1 February | 2002 | 6% |
1 February | 2009 | 3% |
1 June | 2009 | 1.5% |
1 July | 2009 | 0.5% |
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