PMD Business Finance Holdings Ltd v Lee Schofield & Anor [2026] EWHC 10 (KB) (05 January 2026)

PMD Business Finance Holdings Ltd v Lee Schofield & Anor [2026] EWHC 10 (KB) (05 January 2026)

The requirements of CPR 31.16 for pre-action disclosure were satisfied: the parties were likely to be parties to subsequent proceedings, the documents sought fell within standard disclosure, and disclosure was desirable to clarify the issues, potentially resolve the dispute without proceedings, or save costs. The order was proportionate and not a fishing expedition.

Citation
[2026] EWHC 10 (KB)
Parties
Claimant: PMD Business Finance Holdings Limited; Defendant: Lee Schofield; Defendant: One Funding Limited
Jurisdiction
England and Wales
Judgment Date
05 January 2026
Procedural Posture
Pre Action Disclosure Application / Judgment on Application for Pre Action Disclosure Under CPR 31.16
Outcome
Application granted with limitations
Legal Topics
Pre Action Disclosure, Restrictive Covenants, Breach of Contract, Inducement of Breach, Confidential Information
Civil Procedure Contract Law Employment Law Pre Action Disclosure Restrictive Covenants Breach of Contract Inducement of Breach Confidential Information

Case Brief

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Parties

PMD Business Finance Holdings Limited

Claimant

Lee Schofield

Defendant

One Funding Limited

Defendant

Procedural Posture

Pre Action Disclosure Application / Judgment on Application for Pre Action Disclosure Under CPR 31.16

Legal Issues

  1. 1 Whether the requirements for pre-action disclosure under CPR 31.16 are satisfied
  2. 2 Whether the documents sought fall within standard disclosure
  3. 3 Whether pre-action disclosure is desirable to dispose fairly of anticipated proceedings, assist resolution, or save costs

Ratio Decidendi

The requirements of CPR 31.16 for pre-action disclosure were satisfied: the parties were likely to be parties to subsequent proceedings, the documents sought fell within standard disclosure, and disclosure was desirable to clarify the issues, potentially resolve the dispute without proceedings, or save costs. The order was proportionate and not a fishing expedition.

Court Disposition

Application granted with limitations

Orders

  • Respondents to disclose and permit inspection of specified documents relating to communications, transactions, and meetings with Restricted Customers, Suppliers, and Introducers from 12 November 2023 to 1 May 2025.
  • Respondents to specify which documents are no longer in their control and the reasons, and identify documents withheld from inspection.