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Resisting Without Notice Interim Injunctions: Compliance, Set Aside and Return Date Tactics under CPR Part 25 (April 2025, England and Wales)

Checklists
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This Checklist is intended to help practitioners adopt a structured method for resisting a without‑notice application for an interim injunction.

It should be read in conjunction with the detailed guidance contained in the following Practice Notes:

  • Interim injunctions—without notice applications
  • Interim injunctions—the American Cyanamid guidelines
  • Interim injunctions—drafting the order

Although this Checklist concentrates on without‑notice applications, there is inevitably some cross‑over with matters that arise on on‑notice applications. Practitioners should therefore also familiarise themselves with the detailed guidance contained in: Opposing an on notice interim injunction application—checklist as well.

6 April 2025 changes

With effect from 6 April 2025, the CPR provisions governing interim injunctive relief were amended. In particular, CPR 25 underwent extensive revision, and the related Practice Directions were revoked. This revocation covered the example draft orders found in Annex A and Annex B to Practice Direction 25A. In addition, three new ‘model orders’ came into force on 6 April 2025. The reforms were not intended to produce any material change to the substantive law or to practice; however, many provisions were renumbered and their locations altered...

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Web page updated on 20/05/2026

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