QRT v JBE (Rev1) [2025] EWHC 1561 (KB) (23 June 2025)

QRT v JBE (Rev1) [2025] EWHC 1561 (KB) (23 June 2025)

The Defendant breached the Order of 8 September 2022 by failing to disclose at least one device used during the relevant period, warranting a remedial/coercive order requiring further disclosure and delivery up of devices, with strike out of Defence as a sanction for non-compliance.

Citation
[2025] EWHC 1561 (KB)
Parties
Claimant: QRT; Defendant: JBE
Jurisdiction
England and Wales
Judgment Date
23 June 2025
Procedural Posture
Misuse of Private Information / Post Interim Injunction, Application for Terminating Ruling and Compliance Order
Outcome
Remedial/coercive order granted; adjournment application refused; Defence not struck out at this stage; summary judgment refused.
Legal Topics
Misuse of Private Information, Injunctive Relief, Compliance With Court Orders, Electronic Evidence, Summary Judgment, Strike Out
Privacy Law Civil Procedure Misuse of Private Information Injunctive Relief Compliance With Court Orders Electronic Evidence Summary Judgment Strike Out

Case Brief

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Parties

QRT

Claimant

JBE

Defendant

Procedural Posture

Misuse of Private Information / Post Interim Injunction, Application for Terminating Ruling and Compliance Order

Legal Issues

  1. 1 Whether the Defendant breached court orders by failing to disclose all relevant electronic devices
  2. 2 Whether the Defence should be struck out or summary judgment granted
  3. 3 Appropriate remedial/coercive orders for non-compliance

Ratio Decidendi

The Defendant breached the Order of 8 September 2022 by failing to disclose at least one device used during the relevant period, warranting a remedial/coercive order requiring further disclosure and delivery up of devices, with strike out of Defence as a sanction for non-compliance.

Court Disposition

Remedial/coercive order granted; adjournment application refused; Defence not struck out at this stage; summary judgment refused.

Orders

  • Defendant to provide further witness statement within 7 days identifying concealed phone and any other undisclosed devices used during relevant period.
  • Defendant to deliver up any such devices to SJE for inspection and imaging within 14 days.