CPR r31.22 provides that a party to whom a document is disclosed may use the document only for the purposes of the proceedings in which it is disclosed, except where the court gives permission. The court can make an order restricting the use of a document even where the document has been read to or by the court on an application by "a party" or any person to whom the document belongs.

Unusually in this case, the party to whom a document was disclosed wished to restrict its use (and prevent the document being used in proceedings in Cyprus). Leggatt J rejected an argument that he had no jurisdiction to make an order restricting the use of the document in such circumstances: "there is nothing in the wording of the rule which circumscribes who may apply for an order restricting or prohibiting the use of a disclosed document. To the contrary, paragraph 3 expressly states that an application for such an order may be made "by a party". It does not limit the application to the party to whom the document has been disclosed, nor can I see any good reason to imply such a restriction into the rule. In particular, I can see no reason why an application should not be made in an appropriate case by a party to whom a document has been disclosed to seek to restrict the use of that document where the disclosing party has obtained it from a third party, as is the situation here".