Jurisdiction(s):
United Kingdom

Template letter to opponent after inadvertent disclosure of privileged documents: request for return, non-use undertakings, and potential injunction

Published by a LexisNexis Dispute Resolution expert

Precedents

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Dear [ insert organisation name ]

We are writing to notify you that [ we OR our client ] mistakenly provided you with privileged material by means of [ our letter and attachments dated [ insert date ] ] and to seek the prompt return of that material.

The documents concerned are [ identify the documents with precision ].

In relation to [ identify document(s) or classes of document(s) ], they are protected by legal advice privilege. Each is a communication between a lawyer and the client made for the purpose of requesting or delivering legal advice and was, and remains, confidential, or is a record of such a communication that was, and remains, confidential. [ The ‘client’ for these purposes is [ identify ‘client’ group within a corporate body ]. ]

[ In relation to [ identify document(s) or classes of document(s) ], these are protected by litigation privilege...

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Mathew Purchase

Matrix Chambers

Mathew Purchase's practice includes all aspects of employment law, discrimination law, public law and human rights and civil liberties. He is on the Attorney General's B Panel and is a member of the Bar Pro Bono Unit and ELAAS. He is recommended in Chambers and Partners and the Legal 500, which have described him as: ‘extremely intelligent’, ‘just superb - smooth, engaging and perfectly pitched’, and as someone who ‘always does excellent work’. Mathew has broad experience in public law and human rights, including community care, education, housing and civil actions against the police, from early advisory work to judicial review. Mathew has a strong interest in all aspects of education law and acts for parents/children, local authorities and schools at all levels. He has appeared in a number of judicial review claims; recent cases include R (UNISON) v Lord...

Web page updated on 22/05/2026

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