What the Mazur Decision Means for Delegating Litigation Tasks

Firms that delegate litigation tasks to paralegals had reason to worry in the year before this judgment. On 31 March 2026, the Court of Appeal handed down its judgment in CILEX and others v Mazur and others [2026] EWCA Civ 369. For firms that had quietly paused or scaled back delegation to paralegals while an earlier High Court ruling stood, this decision is worth reading properly, not just noting in passing.

Why firms delegate litigation tasks, and what was in dispute

The question before the Court of Appeal was narrow but consequential: can an unauthorised person, such as a paralegal, lawfully carry out steps within the conduct of litigation, a reserved legal activity under the Legal Services Act 2007, when acting for and on behalf of an authorised individual such as a solicitor? An earlier High Court decision had cast doubt on this, unsettling a delegation model many firms had relied on for years.

What the Court of Appeal decided

The Court of Appeal, in a judgment led by Sir Colin Birss, held that an unauthorised person may lawfully perform tasks within the conduct of litigation for and on behalf of an authorised individual, provided that individual retains responsibility for the matter and puts in place appropriate supervisory arrangements. Put simply: the solicitor remains the person carrying on the litigation in the eyes of the law, even where a paralegal is doing the practical work, so long as genuine supervision is in place.

The Law Society’s practice note following the decision, published on 13 April 2026, confirmed that firms could broadly resume the delegation arrangements they had operated under before the High Court ruling.

What “appropriate supervision” actually means

Firms that delegate litigation tasks should not treat this judgment as a blank cheque. Supervision has to be real, not nominal. In practice, that means:

• When you delegate litigation tasks, a named, authorised fee earner retains direction and control of the matter throughout, working with a dedicated paralegal rather than a shared resource.
• Work is reviewed before it is relied on, filed at court, or sent to the other side.
• The paralegal is not making independent legal judgements, they are carrying out tasks the fee earner has directed.
• The firm retains ultimate responsibility to the client and to the regulator for everything done on the matter.

This is exactly the structure that distinguishes lawful delegation from an arrangement where a paralegal is, in substance, running a case unsupervised. The distinction matters as much for an in-house paralegal as it does for an outsourced one.

Why this matters beyond the specific case

Mazur is significant because it removes a live legal uncertainty that had made some firms cautious about delegation generally, including to their own paralegals, not just to outsourced support. A firm building or reviewing its supervision arrangements now has a recent, binding statement from the Court of Appeal to work from rather than an unsettled question.

Our own How It Works page sets out exactly how supervision is structured when work is delegated to us, built around the same principles the Court of Appeal confirmed.