Intended audience:

6 hours

Plenary sessions, brief case studies and mock applications for specific disclosure orders

The objectives of this course are to:

  • Give delegates a sound grasp of all aspects of disclosure of documents, from pre-action disclosure (pursuant to protocols or by order) to conclusion of an action, including, in particular, all types of privilege
  • Remind delegates of solicitors’ and clients’ obligations when dealing with documents in the context of litigation under the Common Law and the CPR
  • Equip delegates to prepare and present or oppose applications for further specific disclosure


  • Origin and purpose of CPR part 31
  • Solicitors’ duties to preserve documents (ensure that clients do likewise) and to educate clients in regard to disclosure
  • Pre-action disclosure: protocols and orders
  • Early disclosure on or after commencement of proceedings
  • Standard disclosure under R31.6
  • Privilege from disclosure and inspection
  • Specific disclosure and inspection orders
  • Preparing and presenting an application for an order for further specific disclosure – what to expect and how to deal with it

Case study exercises:
Delegates consider and discuss up to 20 brief factual scenarios to test their understanding of the principles set out in presentations by the trainer, and prepare and role play an application to a High Court Master for an order for specific disclosure.

The success measures of the course are that delegates:

  • Gain an in-depth understanding of all aspects of disclosure, and in particular privilege
  • Appreciate their extensive professional obligations to the court and the client in relation to the preservation and disclosure of documents
  • Gain confidence in preparing, presenting and opposing applications for specific disclosure

The Training Team

Mark Engleman

Arthur Moore

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To find out more or to book a course

Contact Rachel Berry by either using the contact us form, emailing, or calling 01454 550066

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