Lowin will come as some comfort to Claimant lawyers curently reeling from SCCO first instance decisions on proportionality in the BNM and May cases. The Higher Courts message is now even clearer than it was post Broadhurst. Part 36 offers should be made in both the substantive claim and within the costs proceedings, unless there is good reason not to. The writer cannot think of a good reason why a Part 36 offer could not be made at some stage of each process.