In Greene Wood & Mclean v Templeton Insurance Ltd – Lawtel 12.2.09 the Court of Appeal held that for a claim to be "in respect of a contract" within the meaning of CPR r.6.20(5)(c) it was not necessary for the claim to be in respect of a contract between the intended claimant and the intended defendant, and it was enough that only one of the parties to the intended action was a party to the contract.

To say that, for a claim to be "in respect of a contract", it had to be "in respect of a contract between the intended claimant and the intended defendant" was to add words to the rule.