Jurisdiction(s):
United Kingdom

Client Letter Template: Interim Injunction Applications in England and Wales — Legal Test, Procedure, Evidence, Full and Frank Disclosure, Costs and Cross‑Undertaking

Published by a LexisNexis Dispute Resolution expert

Precedents

[ Date ]

[ Client's name and address ]

Dear [ insert client name ]

Re: Injunctive relief

I write to advise you regarding your intended application for an interim injunction against [ name of party ], sought in order to [ insert reason for and type of injunctive relief being sought ].

An injunction is a court order that compels a party to carry out a particular act (a mandatory injunction) or prevents a party from undertaking a particular act (a prohibitory injunction), either compelling performance or restraining conduct.

The purpose of an interim injunction is to preserve the existing position and/or reduce potential unfairness ahead of a claim or issue being resolved.

When deciding whether to grant such relief, the court will consider whether, among other matters:

there is a serious issue to be tried;
damages would probably be an adequate remedy for any loss that might be suffered if the injunction were refused;
granting relief before trial would keep a fair balance between the parties’ respective rights;
any other pertinent factors...

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Richard Clayman

Kingsley Napley

My experience covers a broad range of commercial disputes, with a particular focus on civil fraud cases, and disputes involving shareholders, directors and partnerships. I act for both claimants and defendants, often in complex, multi-jurisdiction and high-value claims. I am experienced in obtaining a variety of interim remedies, including worldwide freezing orders, injunctions, security for costs and disclosure orders on behalf of his clients. I have successfully brought and defended various high-profile and legally significant cases. Notwithstanding this, I strive to find ways through conflict that meet my client’s objectives in an efficient and cost-effective way. I have acted for individual and corporate clients from a range of backgrounds and jurisdictions, and across an array of industries including sports and media, retail, sustainable development, construction, energy, finance and shipping....

Anna O’Carroll

Kingsley Napley

Anna is a solicitor in the Dispute Resolution team at Kingsley Napley LLP. Anna acts in a broad range of disputes including high value corporate and contractual disputes, multi-jurisdictional fraud cases, intellectual property, and professional negligence claims. She has particular expertise in acting for domestic and international clients on complex, multi-jurisdictional, trust, estate and Court of Protection disputes....

Web page updated on 22/05/2026

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