Jurisdiction(s):
United Kingdom

Objecting to and Challenging Inspection: Control, Proportionality, Privilege, PII and CMP under CPR 31.19 (England and Wales)

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Practice notes

Grounds for objecting to inspection

In general, a party is entitled to inspect documents that:

have been disclosed to them under CPR 31.3—for general guidance on inspection, see Practice Note: Disclosure—inspection
are referred to in a statement of case, a witness statement, and the like—for further detail, see Practice Note: Disclosure—inspection—Inspection of documents referred to in statements of case, witness statements
are identified in an expert report under CPR 35.10(4)—for additional guidance, see Practice Note: Disclosure—inspection—What can be inspected?

Nonetheless, there are instances where the disclosing party is obliged or entitled to refuse inspection of certain documents under CPR 31.3(1)(b) and CPR 31.19(3). Grounds for resisting inspection include:

irrelevance rendering the documents not disclosable—for more detail, see Practice Note: Disclosure—standard disclosure and the reasonable search
loss of the disclosing party’s control over the documents—for more detail, see below
under CPR 31.3(2), if a party considers it disproportionate to allow inspection of documents within a category or class disclosed under CPR 31.6(b), it need not permit inspection of that category or class

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Web page updated on 21/05/2026

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