Practice – Service. A person, such as the driver of the car involved in the accident with the respondent, who was not just anonymous, but could not be identified with any particular person, could not be sued under a pseudonym or description, unless the circumstances were such that the service of the claim form could be effected or properly dispensed with. The Court of Appeal, Civil Division, had erred in allowing the respondent permission to amend the claim form so as to sue an unnamed defendant. Accordingly, the Supreme Court allowed the appellant insurer's appeal, set aside the order of the Court of Appeal, and reinstated the district judge's order.