Arbitration document production: worked example of a Redfern schedule of requests, objections, replies and tribunal orders, addressing privilege, confidentiality and redactions, and proportionality under the IBA Rules
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Precedents
Claimant’s description of documentation requested
1. All communications and correspondence exchanged from 1 January 2015 to 30 December 2020 between the respondent and each of its suppliers, relating to extensions of time for deliveries.
Claimant’s position on relevance and materiality
The claimant contends that the respondent routinely granted its suppliers additional time for delivery and seized upon the claimant’s single instance of late delivery as a pretext to terminate the Agreement for purely financial motives. These communications, which the respondent ought properly to have retained, would confirm and evidence this.
Respondent’s response to the claimant’s requests and reasons
The respondent objects to the request on the basis that it seeks an overly broad category of documents, the identification and production of which would be burdensome. It is not a narrow and specific set as required by Article 3(a)(ii) of the IBA Rules. Furthermore, whether other suppliers were afforded extensions during the six-year period is not relevant to the pleaded issues and does not affect the parties’ contractual rights.
Any reply from the claimant on the respondent’s response to requests
The claimant maintains its request.
The tribunal’s decision and/or order
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Web page updated on 22/05/2026
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