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Disclosure of Part 36 offers
CPR 36.13(2) provides that the fact that a Part 36 offer has been made must not be drawn to the attention of the trial judge "until the case has been decided". The words “the case” are used in the sense of “the action” or “the proceedings”. This prevents the disclosure of a Part 36 offer to the court where the first part of a split trial has been concluded. This problem is going to being reviewed by the Civil Procedure Rule Committee (Beasley v Alexander).
Disclosure of Part 36 offers - Lexology
CPR 36.13(2) provides that the fact that a Part 36 offer has been made must not be drawn to the attention of the trial judge "until the case has been decided". The words “the case” are used in the sense of “the action” or “the proceedings”. This prevents the disclosure of a Part 36 offer to the court where the first part of a split trial has been concluded. This problem is going to being reviewed by the Civil Procedure Rule Committee (Beasley v Alexander).
Disclosure of Part 36 offers - Lexology