Hughes & Ors v World Rugby Ltd & Ors [2025] EWHC 3382 (KB) (22 December 2025)

Hughes & Ors v World Rugby Ltd & Ors [2025] EWHC 3382 (KB) (22 December 2025)

A finding of default is not a legal precondition to the making of an unless order under CPR 3.1(3); the judge's broad case management discretion permits such orders where there is evidence of widespread non-compliance or misapprehension of obligations. The unless orders and related disclosure orders were within the judge's discretion, proportionate, and justified by the procedural context and the need for effective management of complex multi-party litigation. The appeals against the unless orders and related case management decisions are dismissed.

Citation
[2025] EWHC 3382 (KB)
Parties
Applicant/claimant: Adam Hughes & 162 Others; Applicant/claimant: Aakesh Rai & 65 Others; Applicant/claimant: William Evans & 30 Others; Applicant/claimant: Andrew Bishop & 59 Others; Applicant/claimant: Aiden Colvin & 64 Others; Applicant/claimant: Smedley & 387 Others; Applicant/claimant: Michael Edwards & 120 Others; Applicant/claimant: Adam Palfrey & 20 Others; Applicant/claimant: Alan Hodgkinson & 33 Others; Respondent/defendant: World Rugby Limited; Respondent/defendant: Welsh Rugby Union Limited; Respondent/defendant: Rugby Football Union; Respondent/defendant: Rugby Football League Limited; Respondent/defendant: British Amateur Rugby League Association Limited
Jurisdiction
England and Wales
Judgment Date
22 December 2025
Procedural Posture
Appeal (case Management Orders in Multi Party Personal Injury Claims) / High Court (king's Bench Division) Judgment on Appeal Against Unless Orders and Related Case Management Decisions
Outcome
Appeals dismissed
Legal Topics
Case Management Orders, Unless Orders, Disclosure Obligations, Relief From Sanctions, Multi Party Litigation, Group Litigation, Personal Injury (brain Injury), Sports Governing Body Liability
Civil Procedure Personal Injury Sports Law Case Management Orders Unless Orders Disclosure Obligations Relief From Sanctions Multi Party Litigation +3 more

Case Brief

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Parties

Adam Hughes & 162 Others

Applicant/claimant

Aakesh Rai & 65 Others

Applicant/claimant

William Evans & 30 Others

Applicant/claimant

Andrew Bishop & 59 Others

Applicant/claimant

Aiden Colvin & 64 Others

Applicant/claimant

Smedley & 387 Others

Applicant/claimant

Michael Edwards & 120 Others

Applicant/claimant

Adam Palfrey & 20 Others

Applicant/claimant

Alan Hodgkinson & 33 Others

Applicant/claimant

World Rugby Limited

Respondent/defendant

Welsh Rugby Union Limited

Respondent/defendant

Rugby Football Union

Respondent/defendant

Rugby Football League Limited

Respondent/defendant

British Amateur Rugby League Association Limited

Respondent/defendant

Procedural Posture

Appeal (case Management Orders in Multi Party Personal Injury Claims) / High Court (king's Bench Division) Judgment on Appeal Against Unless Orders and Related Case Management Decisions

Legal Issues

  1. 1 Whether a finding of default is a legal precondition to making an unless order under CPR 3.1(3)
  2. 2 Whether the unless orders made were disproportionate, oppressive, irrational or perverse
  3. 3 Whether the orders for disclosure of medical records and testing process documents were lawful and proportionate

Ratio Decidendi

A finding of default is not a legal precondition to the making of an unless order under CPR 3.1(3); the judge's broad case management discretion permits such orders where there is evidence of widespread non-compliance or misapprehension of obligations. The unless orders and related disclosure orders were within the judge's discretion, proportionate, and justified by the procedural context and the need for effective management of complex multi-party litigation. The appeals against the unless orders and related case management decisions are dismissed.

Court Disposition

Appeals dismissed

Orders

  • Unless orders and related case management orders upheld
  • No finding that a prior default is required for unless orders under CPR 3.1(3)