Can lay litigants be compensated for their time spent working on a case?

The difficulty that would arise if lay litigants were allowed compensation for their time spent on a case was addressed by Danckwerts L.J. in Bucklands. At p. 36 he said [quoting Bowen L.J. in London Scottish Benefit Society v. Chorley, infra, at pp. 876-7]: "Professional skill and labour are recognized and can be measured by the law; private expenditure of labour and trouble by a layman cannot be measured."