The High Court has ruled that para 4.1 CPR PD6A re Service within the UK allows a party to supply only one email address (or fax number or other electronic identification) for service by electronic means. Where the party serving is given several email addresses, it is not free to choose between them, but should instead ask which single email address to use, or alternatively serve by other permitted means
This judgment in R (Tax Returned Ltd) v HMRC [2022] EWHC 2515 (Admin) has significant implications. For many lawyers and law firms, requesting service to more than one email recipient is a risk management practice intended to avoid important documents being missed if a particular person is unavailable or absent. It will be interesting to see if this decision is challenged or distinguished in the near future or other formal guidance issued to clarify the application of CPR PD6A. However, this case represents the position for now and, as we come towards the end of the year which is often a particularly busy time for service deadlines – forewarned is forearmed!