Blanket refusal. 'Extemporary' proves errors exist.
Cohen refused all 7 CPR 40.12 correction requests without engaging with them individually. The sealed order contains 'extemporary' (a non-word) and other errors. The order was sealed with uncorrected mistakes.
CPR 40.12
What the opponent will argue, and why they are wrong.
Judge has discretion whether to exercise slip rule.
Cohen refused all 7 corrections without addressing ANY individually. His blanket refusal ('My Order adequately expresses what I intended') fails to engage with the substance. Order sealed with 'extemporary' (a non-word). CPR 40.12 exists to correct errors. Blanket refusal defeats its purpose. Egan v Motor Services: slip rule is the proper mechanism.
Minor typographical errors do not invalidate an order.
'Extemporary' is not merely a typo. It is a non-word that does not exist in English. But the CPR 40.12 application concerned substantive matters beyond typos: the scope of the order, the costs provisions, and the TWM certification. Cohen refused to engage with any of them. The blanket refusal is reviewable.
Fallback: This is a supporting ground reinforcing the pattern of procedural unfairness. Not essential to the outcome.
Independence: Partially dependent on other grounds succeeding.
| Date | Judge | Type | Status |
|---|---|---|---|
| 19 August 2025 | Recorder Cohen KC | Summary Judgment Order | VOID |