Forsters LLP v Uddin [2025] EWHC 3255 (KB) (11 December 2025)

Forsters LLP v Uddin [2025] EWHC 3255 (KB) (11 December 2025)

The Defendant received confidential and privileged documents as a result of an obvious and acknowledged mistake in response to a DSAR. The Defendant knew or ought to have known the disclosure was erroneous. The court's equitable jurisdiction requires the Defendant to deliver up and delete all such documents and...

Source-derived case information.

Citation
[2025] EWHC 3255 (KB)
Parties
Claimant: Forsters LLP; Defendant: Zia Uddin
Jurisdiction
England and Wales
Judgment Date
11 December 2025
Procedural Posture
Interim Injunction Application (breach of Confidence) / Interlocutory (application for Interim Relief)
Outcome
Interim injunction granted in favour of the Claimant.
Legal Topics
Breach of Confidence, Legal Professional Privilege, Inadvertent Disclosure, Data Subject Access Request (dsar), Interim Injunctions, Confidential Information, Data Protection Law
Equity Civil Procedure Data Protection Breach of Confidence Legal Professional Privilege Inadvertent Disclosure Data Subject Access Request (dsar) Interim Injunctions +2 more

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Parties

Forsters LLP

Claimant

Zia Uddin

Defendant

Procedural Posture

Interim Injunction Application (breach of Confidence) / Interlocutory (application for Interim Relief)

Legal Issues

  1. 1 Whether the Defendant should be compelled to deliver up and delete confidential and privileged documents disclosed by mistake in response to a DSAR
  2. 2 Whether the Defendant is entitled to retain or use the documents in ongoing litigation
  3. 3 Whether the inadvertent disclosure constitutes an 'obvious mistake' justifying injunctive relief

Ratio Decidendi

The Defendant received confidential and privileged documents as a result of an obvious and acknowledged mistake in response to a DSAR. The Defendant knew or ought to have known the disclosure was erroneous. The court's equitable jurisdiction requires the Defendant to deliver up and delete all such documents and restrains their use, as privilege and confidentiality must be restored to the extent possible. The Defendant's arguments regarding lawful entitlement, delay, and use are rejected; the balance of justice overwhelmingly favours the Claimant.

Court Disposition

Interim injunction granted in favour of the Claimant.

Orders

  • Defendant to deliver up all 3,300 documents received in error.
  • Defendant to delete all copies of the documents in his possession.