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Civil & Commercial

Some problems can't wait for the normal court timetable.

Urgent applications for injunctions and interim relief, including without-notice and out-of-hours applications where immediate court intervention may be required.

What an injunction does

An injunction is a court order requiring someone to do something (a mandatory injunction) or stop doing something (a prohibitory injunction). Most applications are for interim relief, holding the position until a full trial, rather than a final order. Some situations call for freezing orders, preventing a defendant from dissipating assets, or search orders, preserving evidence before it can be destroyed or moved.

The test the court applies

For most interim injunctions, the court asks whether there is a serious issue to be tried, whether damages would be an adequate remedy if the applicant later wins at trial, and where the balance of convenience lies between the parties until then. Freezing and search orders carry a higher threshold, given how significant their effect can be before the other side has been heard.

The cross-undertaking in damages

An applicant for an interim injunction is normally required to promise to compensate the respondent for any loss the order causes if it later turns out the injunction should not have been granted. This is a real financial commitment, not a formality, and should be understood before an application is made.

Without notice applications

Where advance warning would defeat the purpose of the order, such as a genuine risk that assets or evidence will disappear, an application can be made without notifying the other side first. This comes with a strict duty of full and frank disclosure: the applicant must tell the court about anything that might weigh against granting the order, not only the points in their own favour. Orders obtained without proper disclosure are vulnerable to being set aside.

Speed matters

Genuinely urgent applications can be heard the same day, and in some circumstances out of hours through the emergency court list. Preparation still matters: a clear witness statement, a draft order and an accurate account of the urgency all affect how the application is received.

Urgent civil remedies

The legal framework for an interim injunction

Interim injunctions are governed by CPR Part 25 and the court's underlying jurisdiction, including section 37 of the Senior Courts Act 1981 in the High Court. An application normally requires evidence identifying the legal claim, the threatened or continuing harm and why an interim order is necessary before trial.

The classic approach in American Cyanamid Co v Ethicon Ltd [1975] AC 396 asks whether there is a serious issue to be tried, whether damages would be an adequate remedy and where the balance of convenience lies. The precise approach depends on the type of injunction and the rights engaged; some specialist injunctions have additional tests.

Under CPR Part 25, an interim remedy can be granted before proceedings in urgent or otherwise appropriate cases. A without-notice application requires good reason for proceeding without notice. The applicant must give the court a fair presentation of the relevant facts, and an injunction will usually include a cross-undertaking in damages so that a respondent can seek compensation if the order later proves to have caused loss that should be paid by the applicant.

Key sources: Senior Courts Act 1981 s37; CPR Part 25; American Cyanamid Co v Ethicon Ltd [1975] AC 396. Freezing injunctions, search orders and publication cases have additional requirements.

Frequently asked questions

How quickly can an injunction be obtained?
In a genuinely urgent case an application can be made quickly, sometimes before the substantive claim is issued. Speed depends on the evidence, court availability and whether notice can properly be given.

Can I apply without telling the other side?
Only where there is a proper reason for not giving notice. Without-notice relief is exceptional and carries strict duties, including full and fair disclosure and usually a prompt return hearing where the respondent can be heard.

What evidence is needed?
Usually a detailed witness statement with the relevant documents, chronology, threatened harm and explanation of urgency. The evidence should address both the legal claim and why damages alone would not be an adequate remedy.

What is a cross-undertaking in damages?
It is an undertaking to the court, commonly required from an applicant, to compensate a respondent for loss caused by the injunction if the court later concludes compensation should be paid.

What happens if an injunction is breached?
A deliberate breach can amount to contempt of court and can have serious consequences. The precise enforcement route depends on the order and evidence of breach.

Can an injunction be varied or discharged?
Yes. A respondent can apply to vary or discharge an interim order, and the court can revisit the terms as evidence or circumstances develop.

How much will an urgent application cost?
It depends on urgency, evidence volume, whether counsel is required and how contested the application becomes. We provide a staged estimate after reviewing the papers and explain court fees and counsel's fees separately.