Various Claimants v G4S Plc [2021] EWHC 524 (Ch) (10 March 2021)

Various Claimants v G4S Plc [2021] EWHC 524 (Ch) (10 March 2021)

CPR 17.1 does not permit the addition of new claimants with separate claims before service; such amendments are not valid. Challenges to such amendments may be made under CPR 3.4 and are not subject to the 14-day limit in CPR 17.2. The addition of claimants after issue is disallowed.

Source-derived case information.

Citation
[2021] EWHC 524 (Ch)
Parties
Claimant: Various Claimants (THE PERSONS IDENTIFIED IN SCHEDULE 1); Defendant: G4S PLC
Jurisdiction
England and Wales
Judgment Date
10 March 2021
Procedural Posture
Civil Financial Services / Interlocutory Application Ruling
Outcome
Application granted in favour of G4S; amendments adding claimants after issue disallowed.
Legal Topics
Amendment of Pleadings, Limitation Periods, Addition of Parties, Section 90 a FSMA Claims
Civil Procedure Financial Services Law Amendment of Pleadings Limitation Periods Addition of Parties Section 90 a FSMA Claims

Source-derived case record

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Parties

Various Claimants (THE PERSONS IDENTIFIED IN SCHEDULE 1)

Claimant

G4S PLC

Defendant

Procedural Posture

Civil Financial Services / Interlocutory Application Ruling

Legal Issues

  1. 1 Whether claimants can be added to a claim after expiry of the limitation period under CPR 17.1
  2. 2 Whether amendments to claimant names after limitation period are permissible
  3. 3 Whether G4S's challenge to amendments is procedurally valid given CPR time limits

Ratio Decidendi

CPR 17.1 does not permit the addition of new claimants with separate claims before service; such amendments are not valid. Challenges to such amendments may be made under CPR 3.4 and are not subject to the 14-day limit in CPR 17.2. The addition of claimants after issue is disallowed.

Court Disposition

Application granted in favour of G4S; amendments adding claimants after issue disallowed.

Orders

  • Addition of claimants to the claim form after 10 July 2019 declared ineffective.
  • Claims by claimants added after 10 July 2019 struck out.