Midland Premier Properties Ltd & Anor v Doal & Ors [2026] EWCA Civ 117 (17 February 2026)

Midland Premier Properties Ltd & Anor v Doal & Ors [2026] EWCA Civ 117 (17 February 2026)

The appellants complied with the procedural requirements of the unless order by instructing the e-disclosure provider as specified and supplying the schedule produced. The order did not impose an obligation on the appellants to ensure the completeness or sufficiency of the schedule; their responsibility was limited...

Source-derived case information.

Citation
[2026] EWCA Civ 117
Parties
Claimant: Midland Premier Properties Limited; Claimant/respondent: Sanman Property Management Limited; Defendant: Rakesh Singh Doal; Defendant/appellant: 2020 Living Limited; Defendant/appellant: Samuel Ginda; Defendant/appellant: Taylor Grange 2 Limited; Defendant/appellant in CA 2024 002403: Taylor Grange DM Limited; Defendant/appellant: TGDM One Limited
Jurisdiction
England and Wales
Judgment Date
17 February 2026
Procedural Posture
Appeal / Court of Appeal Judgment
Outcome
Appeal allowed; strike out and debarring orders set aside.
Legal Topics
Unless Orders, Relief From Sanction, Disclosure Obligations, Strike Out, Conspiracy, Inducement of Breach of Contract
Civil Procedure Contract Law Commercial Law Unless Orders Relief From Sanction Disclosure Obligations Strike Out Conspiracy +1 more

Source-derived case record

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 4 Authorities cited 16 Party arguments 2 Amounts and remedies 3
Sign in to unlock

Parties

Midland Premier Properties Limited

Claimant

Sanman Property Management Limited

Claimant/respondent

Rakesh Singh Doal

Defendant

2020 Living Limited

Defendant/appellant

Samuel Ginda

Defendant/appellant

Taylor Grange 2 Limited

Defendant/appellant

Taylor Grange DM Limited

Defendant/appellant in CA 2024 002403

TGDM One Limited

Defendant/appellant

Procedural Posture

Appeal / Court of Appeal Judgment

Legal Issues

  1. 1 Whether the appellants failed to comply with an unless order and should be debarred from defending
  2. 2 Interpretation of procedural orders regarding disclosure and instructions to e-disclosure providers
  3. 3 Whether the trial judge erred in striking out defences for alleged non-compliance

Ratio Decidendi

The appellants complied with the procedural requirements of the unless order by instructing the e-disclosure provider as specified and supplying the schedule produced. The order did not impose an obligation on the appellants to ensure the completeness or sufficiency of the schedule; their responsibility was limited to giving instructions and passing on the product. The trial judge erred in striking out the defences and debarring the appellants from defending based on alleged deficiencies in the schedule, as the unless order was not breached.

Court Disposition

Appeal allowed; strike out and debarring orders set aside.

Orders

  • Defences of the second to sixth defendants reinstated.
  • Matter remitted for further proceedings consistent with this judgment.