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Search and Imaging Orders: Urgent Respondent Checklist under CPR Part 25 (from 6 April 2025) (England and Wales)

Checklists
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This Checklist outlines the principal considerations that respondents must address when replying to an imaging order. It should be read alongside the following Practice Notes:

  • Search and imaging orders—guiding principles
  • Search and imaging orders—making an application
  • The model search and imaging order
  • Search and imaging orders—execution of the order and next steps

For guidance from the viewpoint of an applicant seeking an imaging order, see: Applying for an imaging order—checklist.

6 April 2025 changes

With effect from 6 April 2025, the CPR provisions governing interim injunctive relief, including search and imaging orders, were amended. In particular, CPR 25 was extensively overhauled and the associated Practice Directions—covering the standard draft search order and the imaging order form (previously in Annex A and Annex B to Practice Direction 25A)—were revoked. In their place, a new model search and imaging order came into force on 6 April 2025 (the ‘model search and imaging order’)...

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Christian Toms
Christian Toms

Christian Toms is a partner in SPB’s International disputes team. He regularly advises in a range of matters, with particular experience in complex financial disputes, civil fraud matters, and director/shareholder/joint venture disputes. He has previously acted for and against investment and retail banks, hedge funds and other investor groups. He also has experience in cross-border enforcement, and of evidence gathering and other ancillary orders in support of foreign proceedings.Before joining SPB, Christian was a partner at the US firm Brown Rudnick having initially joined BR as an associate barrister from the then Lovells LLP. Prior to that, he was a tenant in London chambers defending and prosecuting criminal cases. His previous experience at the Criminal Bar gives him an invaluable insight when advising in matters involving contentious regulatory and White Collar issues. Chris has been recognised by the Legal 500 for a number of years and is a...

Web page updated on 20/05/2026

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