Requests for further information about statements of case

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Requests for Further Information About Statements of Case

In civil litigation, it is often necessary for one party to seek additional details or clarifications regarding the opposing party's statements of case. Requests for further information (RFIs) are a formal mechanism provided under the Civil Procedure Rules (CPR), specifically Part 18, allowing parties to obtain such information. These requests help to narrow the issues, clarify ambiguities, and ensure that each party fully understands the other's case.

Purpose of Requests for Further Information

The primary purposes of RFIs include:

  • Clarifying Ambiguities: To clarify any unclear or ambiguous aspects of the statements of case, ensuring that all allegations, defences, and counterclaims are understood.
  • Narrowing Issues: To narrow the scope of the dispute by pinpointing specific issues that are in contention, which can streamline the litigation process and potentially facilitate settlement.
  • Ensuring Fairness: To ensure that all parties have the necessary information to prepare their case, enabling a fair opportunity to respond to the allegations or defences.
  • Preparing for Trial: To gather additional details that may be crucial for trial preparation, including the evidence that will be presented and the legal arguments that will be made.

Case Law: *Swain-Mason and others v. Mills & Reeve (A Firm)* [2011]

In *Swain-Mason v. Mills & Reeve* [2011], the Court of Appeal emphasized that RFIs should not be used as a tactical device to complicate the litigation or cause unnecessary delay. Instead, they should focus on obtaining genuinely necessary information to clarify the issues in dispute. The court discouraged the use of RFIs for fishing expeditions and reiterated the importance of proportionality and relevance.

Structure and Content of Requests for Further Information

An RFI should be clearly drafted and specific in its queries. It should focus on obtaining necessary details without being overly broad or burdensome. Key elements include:

  • Heading and Case Details: The RFI should include a heading that identifies it as a request for further information, along with the case name and number.
  • Specific Questions: A series of specific questions or requests for information. Each question should be numbered and refer to the relevant paragraphs or sections of the statements of case that require clarification or further detail.
  • Scope of the Request: The RFI should indicate the scope of the information sought, ensuring that it is reasonable and proportionate to the issues in the case.

Example: Specificity in RFIs

In a contract dispute, a claimant might issue an RFI requesting clarification on a defendant's assertion that a particular contractual term was not breached. The RFI might ask the defendant to specify the exact actions or inactions that led them to this conclusion, referencing specific clauses in the contract. This precise request helps focus the dispute and avoid unnecessary arguments.

Responding to Requests for Further Information

The party receiving an RFI is generally obliged to respond in a timely manner. The response should address each question directly and provide the requested information or clarify why the information cannot be provided. Key aspects of the response include:

  • Timely Response: The responding party should provide the requested information within a reasonable time frame, as agreed upon or directed by the court.
  • Comprehensive Answers: Responses should be complete and precise, directly addressing the questions asked. If a question cannot be answered, the response should explain the reasons, such as privilege, lack of knowledge, or irrelevance.
  • Statement of Truth: In some cases, a statement of truth may be required, verifying that the responses are accurate to the best of the responding party's knowledge and belief.

Disputes Over Requests for Further Information

Disputes may arise regarding the scope or appropriateness of an RFI. The CPR provides mechanisms to resolve such disputes, including:

  • Objecting to Requests: The responding party may object to providing certain information if it is irrelevant, overly burdensome, or privileged. Objections should be clearly stated in the response.
  • Applications to the Court: If the requesting party believes that the response is inadequate or if the responding party refuses to provide information, they can apply to the court for an order compelling the provision of further information. The court will consider the relevance, necessity, and proportionality of the information sought.

Example: Disputing RFIs

In a personal injury case, the defendant may receive an RFI requesting detailed medical records unrelated to the injury claimed. The defendant could object, arguing that the request is overly broad and irrelevant to the issues at hand. If the claimant insists, the court may need to intervene to decide whether the information is necessary and proportionate.

Conclusion

Requests for further information are an essential tool in civil litigation, facilitating the exchange of necessary details and clarifications between parties. They help to refine the issues in dispute, ensuring that all parties are adequately prepared for trial. Properly handling RFIs—whether making or responding to them—requires careful consideration of the relevance and necessity of the information, adherence to procedural rules, and a commitment to maintaining fairness in the litigation process.

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