Group Actions – Extension Of The Cut-Off Date : CPR 19.13 and The Denton Guidance
This was an application to extend the cut-off date in a group action. The application was framed as one for relief from sanctions (following Holloway v Transform Medical Group (CS) Ltd (PIP Breast Implant Litigation)  EWHC 1641 (QB)). The application was refused on the basis of the guidance laid down by the Court of Appeal in Denton v White Limited and De Laval and others  EWCA Civ 906. However, Stewart J did not consider the decision in Pearce v Secretary of State for Energy and Climate Change (British Coal Coke Oven Workers Litigation)  EWHC 3775 (QB) or the need to avoid an accumulation of residual applications in group actions.