in a whiplash case, whether at the very start of the case, near the end or indeed that of the trial judge when assessing quantum at trial, is precisely the same. The key question the lawyer must ask of himself is:

"Do I trust the Claimant?"

There are many subsidiary questions concerning the Claimant's honesty, his character, his injuries and his loss but lawyers will find time after time that if the judge does not trust the Claimant then the case will either be lost or result in a small award. On the other hand if the judge does trust the Claimant the most fulsome awards may be achieved.

101.2 The basic method Proving or assessing quantum is a simple exercise at heart. It is a mere comparison between the Claimant's life before the accident extended forwards assuming that the accident had not happened and his life afterwards.

101.3 The complications arise in the detail and the methods of proof and rebuttal. So the Claimant's witness statement should concentrate at first on his life, amenity, sports, health, work and ambitions before the accident. Only when these have been covered should the statement move on to deal with the accident, the injuries and the consequential suffering and loss.

101.4 Supporting witnesses If the lawyer harbours doubts about the Claimant's veracity it is often wise to obtain witness statements from members of the close family and work colleagues. A credible witness usually has little difficulty finding supporting witnesses. Incredible Claimants often assert that they can obtain many supporting witness without being able to produce them.

101.5 Receipts Supporting paperwork is a useful tool. There are twin objectives when approaching quantum: to persuade the claims manager of the Defendant's insurance company that the item claimed is a proper one, and secondly to prove to the judge that it is.