Jeremy Warner writes an article on withdrawing pre-action admissions and examines strategy for both claimants and defendants

3rd July 2025

3PB’s specialist personal injury, clinical negligence and inquests barrister Jeremy WarnerJeremy WarnerCall: 2022 looks at applications to withdraw pre-action admissions. Jeremy provides guidance on how defendants should approach these applications and how claimants should respond.

In Somoye v North West Anglia NHS Foundation Trust [2023] EWHC 191 (KB), the High Court offered important guidance on the circumstances in which a defendant may resile from an admission and the hurdles they must overcome. Jeremy examines Somoye alongside the Court of Appeal’s earlier decision in Wood v Days Healthcare UK Limited [2017] EWCA Civ 2097 and shares practical takeaways for both sides.

Jeremy concludes: “Ultimately, while the CPR allows for some flexibility, it is not a tool to escape the consequences of poor strategic decisions. The concept of finality of litigation matters to all litigants who rely on admissions as a procedural anchor.”

To read Jeremy’s full article please click here

Jeremy specialises in personal injury, clinical negligence and inquests. He appears regularly in trials, CCMCs, Stage 3 hearings, strike outs, and relief from sanctions applications. He also recently acted in a 3-day inquest reflecting his experience in sensitive coronial work.

To instruct Jeremy or check his availability, please contact his clerk Jordon Gallifant at [email protected] or call 020 7583 8055.