Michael James Allen v Douglas Graham Alexander Stuart & Anor

Michael James Allen v Douglas Graham Alexander Stuart & Anor

There is no principled reason to refuse inclusion of a penal notice in the sealed order; amendments to CPR 81 reverse the Taray Brokering decision and clarify that a penal notice is a warning notice added as necessary.

Parties
Claimant: Michael James Allen; Defendant: Douglas Graham Alexander; Defendant: Ely Skip Hire Limited
Jurisdiction
England and Wales
Judgment Date
19 March 2026
Procedural Posture
Civil / Addendum Judgment on Interim Injunction Application
Outcome
Request to include penal notice in sealed order granted.
Legal Topics
Interim Injunctions, Undertakings, Penal Notice, Contempt of Court
Civil Procedure Injunctions Interim Injunctions Undertakings Penal Notice Contempt of Court

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Parties

Michael James Allen

Claimant

Douglas Graham Alexander

Defendant

Ely Skip Hire Limited

Defendant

Procedural Posture

Civil / Addendum Judgment on Interim Injunction Application

Legal Issues

  1. 1 Whether a penal notice should be included in the sealed order containing undertakings

Ratio Decidendi

There is no principled reason to refuse inclusion of a penal notice in the sealed order; amendments to CPR 81 reverse the Taray Brokering decision and clarify that a penal notice is a warning notice added as necessary.

Court Disposition

Request to include penal notice in sealed order granted.

Orders

  • Parties invited to submit a final draft order in agreed form including penal notice.