Where it had not been shown that, before after-the-event insurance had been taken out and a conditional fee agreement entered into, proper enquiries had been made by a claimant's legal representatives into whether the claimant's liability for costs was covered by any pre-existing insurance, there had been a material breach of the Conditional Fee Agreements Regulations 2000 reg.4(2)(c) and the conditional fee agreement was unenforceable and no costs were recoverable.