“… where an issue has clearly not been pleaded and was not relied on at the start of the trial, I consider that the onus lies as much on counsel for the party seeking to rely on it as on their opponent to raise the matter with the judge and seek permission to amend. For the reasons given by Dyson LJ in Al-Medenni v Mars, a party is entitled to rely on the pleaded case as defining the ambit of the issues to be decided at trial.”

Mr Justice Fancourt in  Jacobs v Chalcot Crescent (Management) Company Ltd [2024] EWHC 259 (Ch) 

This webinar takes a close look at the rules relating to drafting statements of case.

• What should be on the claim form?
• What must the particulars of claim contain?
• Problem areas in drafting the particulars
• What must the claimant plead?
• What should the defence contain?
• When do you need to file a reply or a defence to counterclaim?
• Part 18 requests – what can, and what can’t, they contain?
• Amending statements of case
• Statements of case at trial
• Avoiding the pitfalls of pleading