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Proprietary and freezing injunctions post‑April 2025 in England and Wales: illustrative case summaries and practical points on CPR 25 reforms and the model proprietary and freezing order

Practice notes
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This Practice Note

This Practice Note provides a synopsis of illustrative decisions on applications for proprietary freezing injunctions from April 2025 onwards. It aims to convey the breadth of factual patterns and questions that can emerge in relation to these orders. For significant and illustrative rulings predating April 2025, see Practice Note: Proprietary freezing injunctions—key and illustrative decisions (pre-April 2025) [Archived]. For detailed guidance on the governing principles in proprietary freezing injunction matters, consult Practice Note: Proprietary freezing injunctions. Be aware that the CPR provisions concerning interim injunctive relief—covering both proprietary and freezing orders—were amended with effect from 6 April 2025. In particular, CPR 25 underwent substantial revision and the associated Practice Directions, together with the specimen draft orders contained in Annex A and Annex B to Practice Direction 25A, were revoked. From 6 April 2025, new model orders took effect, including a fresh model order for a freezing injunction, and an alternative model to be used ‘where both a proprietary injunction and a freezing injunction with related disclosure relief are being sought’ (see the ‘Important Note’ on the first page of the model orders)...

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Web page updated on 21/05/2026

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Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...

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I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...

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