Legal Precedents

[ ON YOUR LETTERHEAD ] [ WITHOUT PREJUDICE SAVE AS TO COSTS ] [ Insert date ] [ Insert name and address of other party’s solicitor ] Dear [ insert contact name ] [ Insert subject of letter ] We refer to our open letter of [ today’s date OR [ insert date ] ]. As explained in that correspondence, both we and our client take the view that your client’s allegations against our client (as set out in your client’s letter dated [ insert date ] (the Letter of Claim)) are entirely without foundation and, if pursued before the court, would be rejected in full. In those circumstances, our client will seek to recover from your client all costs it has incurred in addressing this matter. Furthermore, in addition to seeking such costs from your client, should proceedings be issued against our client, our client will bring a...

[ ON YOUR LETTERHEAD ] WITHOUT PREJUDICE SAVE AS TO COSTS [ SUBJECT TO CONTRACT ] [ Insert date ] [ Insert name and address of other party’s solicitor ] Dear [ insert contact name ] [ Insert subject of letter ] We refer to our open letter of [ today’s date OR [ insert date ] ]. As explained in that correspondence, both we and our client remain assured that, were your client to commence proceedings in relation to the alleged claim described in your letter of claim dated [ insert date ] (the ‘ Letter of Claim’), our client would be entirely successful in resisting and defeating any such claim......

[ ON YOUR LETTERHEAD ] WITHOUT PREJUDICE SAVE AS TO COSTS [ SUBJECT TO CONTRACT ] [ Insert date ] [ Insert name and address of other party’s solicitor ] Dear [ insert contact name ] [ Insert subject of letter ] We write further to our open letter dated [ today’s date OR [ insert date ] ]. 1 As explained therein, both we and our client remain assured that our client will entirely succeed in resisting your client’s claim [ s ] against it, arising from the agreement between our respective clients dated [ insert date ] (the ‘ Agreement’), as described in your client’s claim [ insert claim action number ] and in the particulars of claim dated [ insert date of particulars of claim ] (together, ‘the Claim’)......

[ ON YOUR LETTERHEAD ] WITHOUT PREJUDICE SAVE AS TO COSTS [ SUBJECT TO CONTRACT ] [ Insert date ] [ Insert name and address of other party’s solicitor ] Dear [ insert contact name ] [ Insert subject of letter ] We refer to our open correspondence of [ today’s date OR [ insert date ] ]. Our client is satisfied that, were it to commence and pursue proceedings in relation to its claim (as described in our letter of claim dated [ insert date ] (the ‘ Letter of Claim’)), it would be entirely successful in [ insert details of the remedy sought, eg recovering payment of the outstanding invoices together with interest, payable under the Agreement as explained in our open letter ]. [ Our client also considers that your client’s threatened counterclaim, as set out in your letter dated [ insert date ] (the ‘...

[ ON YOUR LETTERHEAD ] WITHOUT PREJUDICE SAVE AS TO COSTS [ SUBJECT TO CONTRACT ] [ Insert date ] [ Insert name and address of other party’s solicitor ] Dear [ insert contact name ] [ Insert subject of letter ] We write further to our open correspondence of [ today’s date OR [ insert date ] ]. As outlined in that correspondence, both we and our client are satisfied that our client will achieve complete success in its claim[ s ] against your client, arising from the agreement between our clients dated [ insert date ] (the ‘ Agreement’). That position is advanced in claim [ insert claim action number ], and our client will [ insert details of the remedy sought, eg, recover payment of the unpaid invoices plus interest, pursuant to the agreement between our respective clients, as set out in our open letter ]. [ It is also our...

Submitted on behalf of the claimant Witness Statement of [ insert initial and surname of witness ] Witness statement number: [ insert number of witness statement in relation to the witness ] Exhibits referenced: [ insert initials and number of each exhibit referred to ] Date statement signed: [ insert date ] [ Translation date: [ insert date ] ] IN THE COUNTY COURT AT [ location ] Claim No. [ insert number ] Parties: [ name ] ( Claimant, a child) by [ name ] as litigation friend, and [ name ] ( Defendant) WITNESS STATEMENT OF [ insert full name ] I, [ insert full name ], of [ insert full address and occupation or, if none, description ], intend to rely upon the following evidence in support of this application. This statement is based on my own knowledge and belief, unless stated...

Submitted on behalf of the claimant Statement of evidence by [ insert initial and surname of witness ] Witness statement number: [ insert number of witness statement in relation to the witness ] Exhibits: [ insert initials and number of each exhibit referred to ] Date statement signed: [ insert date ] [ Date of translation: [ insert date ] ] IN THE COUNTY COURT AT [ location ] Claim number: [ insert number ] Parties [ name ] Claimant (a protected party by [ name ] his [ family relationship ] litigation friend) and [ name ] Defendant WITNESS STATEMENT OF [ insert name ] I, [ insert full name ], of [ if the witness is making the statement in their professional, business or other occupational capacity, insert the address at which they work, the position they hold and the name of their firm or employer ], acting as Legal...

Filed on behalf of the claimant Witness Statement of [ insert initial and surname of witness ] Statement number: [ insert number of witness statement in relation to the witness ] Exhibit references: [ insert initials and number of each exhibit referred to ] Date of statement: [ insert date ] [ Date of translation: [ insert date ] ] IN THE HIGH COURT OF JUSTICE [ [ SPECIFY DIVISION ] ] • [ [ INSERT LOCATION ] DISTRICT REGISTRY ] Claim No. [ insert number ] Parties: A Claimant and B Defendant WITNESS STATEMENT OF [ insert full name ] I, [ insert full name ], of [ insert full address and occupation ], state as follows: This statement is based on my own knowledge and belief unless stated to the contrary. I am the [ mother OR father ] of the...

Filed on behalf of the Claimant Statement of [ insert initial and surname of witness ] Statement number: [ insert number of witness statement in relation to the witness ] Exhibits: [ insert initials and number of each exhibit referred to ] Statement date: [ insert date ] [ Translation date: [ insert date ] ] [ At the County Court at [ INSERT ] or the High Court of Justice ] [ Division: [ SPECIFY DIVISION ] ] [ Specialist Court: [ SPECIFY SPECIALIST COURT ] ] [ District Registry: [ INSERT LOCATION ] ] Claim number: [ insert number ] Between A Claimant and B Defendant WITNESS STATEMENT OF [ INSERT FULL NAME ] I, [ insert full name ], of [ insert full address and occupation ], state as follows: Unless otherwise indicated, the facts and matters set out in this...

Extended Disclosure list of documents for the [ Claimant OR Defendant ] [ Provide details of the proceedings ] Date Document or [ Specify class of document ] Description 1. 2. 3. ......

[ Add details of proceedings ] Initial Disclosure list of documents for the [ Claimant OR Defendant ] Date Document or outline of category of documents Explanation ......

IN THE COUNTY COURT AT [ insert ] Claim No. [ insert number ] Parties (1) AA (2) BB Claimants -and- CC Defendant PARTICULARS OF CLAIM At all material and relevant times, the Defendant carried on trade in the capacity of a tour operator, supplying package holidays to travellers. On 2 July 2025, the First Claimant accessed the Defendant’s website and concluded a contract to purchase a package holiday in Greece from the Defendant. Pursuant to that agreement, the First Claimant and her husband, the Second Claimant, were to depart East Midlands Airport for Athens on 8 August 2025, with an onward transfer thereafter to Santorini. The contract also provided for their return on 15 August 2025, travelling from Santorini to Athens and then onwards back to East Midlands Airport. Following completion of the flight arrangements, the Defendant, by means of a website link,...

This template serves as a provisional ‘litigation hold’ or ‘document retention’ communication, intended for issue by a party (or would‑be party) to proceedings in the Business and Property Courts, where the Disclosure Scheme applies under CPR PD 57AD, para 4.2 and CPR PD 57AD, para 4.3. [ Insert name and address of recipient ] [ Insert date ] PRIVATE, CONFIDENTIAL AND PRIVILEGED Dear [ insert recipient ] Document preservation notice—[ insert subject matter ] We contact you in relation to [ your current employment OR your previous employment OR your current professional relationship OR your previous professional relationship ] with [ insert name of the Company OR name of actual or prospective party to the proceedings ]. [ The Company OR name of actual or prospective party to the proceedings ] [ has recently OR is likely to ] be involved in legal proceedings (‘the...

[ Insert recipient’s name and address ] [ Insert date ] Dear [ insert recipient’s name ] [ Insert case name and claim number ] [ We represent the [ Claimant OR Defendant ] in this matter. ] Please find enclosed, for service, the [ Particulars of Claim OR Defence OR Defence and Counterclaim ], which [ has OR have ] also been lodged at court today [ together with a copy of this correspondence ]. As these proceedings fall within the disclosure scheme of the Business and Property Courts, the [ Claimant OR Defendant ] confirms that, in accordance with para 4.5 of Practice Direction 57AD of the Civil Procedure Rules (‘ CPR PD 57AD’), steps have been taken by the [ Claimant OR Defendant ], and by us as their legal representatives, to preserve relevant documents. [ We also enclose, by way of Initial Disclosure and in...

[ Insert recipient’s name and address ] [ Insert date ] PRIVATE, CONFIDENTIAL AND PRIVILEGED Dear [ insert recipient’s name ] [ Insert case title and claim reference ] We [ are a firm of solicitors and ] represent [ name of client ], your [ former ] employer. We write further to [ our OR [ name of (former) employer ] ] letter dated [ insert date ] [ , a copy of which is enclosed for your ease of reference ]. In addition to [ the Company’s OR the organisation’s ] responsibility to retain any ‘documents’ that could be relevant to the proceedings, [ the Company OR the organisation ] must also, among other requirements, provide to its opponent[ s ] in the proceedings a variety of ‘documents’ pertinent to the dispute and, in particular, those that are or might be ‘adverse’ to its case......

IN THE [ County Court at [ Insert ] or High Court ] Claim No: [ Insert claim number ] Parties [ Mrs Jane Bloggs ] — Claimant [ A Care Home ] — Defendant PARTICULARS OF CLAIM The parties At all relevant times, the Claimant was under the care of the Defendant, through its staff or agents, in relation to her nursing and personal care. Throughout the relevant period, the Defendant ran, directed and oversaw a private residential care home called [ A Care Home ], located at [ Address ] (‘the care home’). ......

Dear [ insert expert’s name ] Claimant’s name: [ insert Claimant’s full name including title ] Claimant’s address: [ insert address ] Claimant’s date of birth: [ insert date of birth ] Date of alleged negligent treatment: [ insert date ] I represent the above-named in relation to injuries said to result from alleged clinical negligence occurring on the date noted. Thank you for agreeing to prepare a report addressing breach of duty/causation/condition and prognosis [ delete as appropriate ] in this matter. Please ensure you fully comprehend any clinical guidance relevant to the issues and that you hold the necessary facts to apply such guidance correctly. You should also be familiar with Part 35 of the CPR, the Practice Direction to Part 35, and the duties and requirements for experts giving expert evidence. In that regard, please see the...

Dear [ insert expert’s name ] Claimant’s name: [ insert Claimant’s full name including title ] Claimant’s address: [ insert address ] Claimant’s date of birth: [ insert date of birth ] Date of alleged negligent treatment: [ insert date ] I represent the above individual in respect of injuries said to have arisen from clinical negligence on the date noted above. We are grateful that you have agreed to prepare a report addressing condition and prognosis for this matter. Kindly ensure you are familiar with Part 35 of the CPR, the Practice Direction to Part 35, together with the obligations and requirements that apply to experts giving expert evidence. For that purpose, I draw your attention to the appendix to this letter of instruction. Your function is to assist the court by offering impartial, independent opinions on issues within your...

Dear [ insert expert’s name ] Re: [ insert name of client and the client’s date of birth, (address and telephone number should be provided separately for the appointment arrangements) ] Date of accident: [ insert date of accident ] Thank you for agreeing to prepare a report on the Claimant’s current condition and prognosis in this matter. We represent the above individual in relation to injuries suffered in an accident on the date noted above. This is a personal injury claim, and our assessment places the likely value of the case between £25,000 and £100,000; we anticipate the court will assign the matter to the intermediate track. Accordingly, your expert report ought not to exceed 20 pages, excluding any requisite photographs, plans, CV, and any academic or technical articles appended to the report. Please ensure proper attention is paid to the appendices...

IN THE [ INSERT COURT ] COURT Claim No [ claim number ] BETWEEN:— [ CLAIMANT’ S NAME ] Claimant and [ DEFENDANT’ S NAME ] Defendant PARTICULARS OF CLAIM The Claimant’s date of birth is [ insert date ]. Throughout the relevant period, the Claimant was under the care of the Defendant, a self-employed general dental practitioner working from premises at [ insert address ] (“the clinic”), who represented [ himself OR herself ] as an experienced, proficient and competent dental professional. The Claimant initially attended an appointment with the Defendant on [ insert date ] for [ insert details of treatment ]. In brief, the Claimant contends that the dental care delivered to [ him OR her ] between [ insert dates ] was negligent as set out in these Particulars of Claim. Consequently, [ insert details of...