Practice – Pre-trial or post-judgment relief. The claimant premiership footballer obtained an ex parte interim order restraining the defendant from disclosing information regarding an alleged sex act that took place between the two. On the return date of the order, the defendant sought to argue that the order should discharged for material non-disclosure. The Queen's Bench Division held that there had been material non-disclosure and that therefore the discharge of the past orders and the refusal of orders for the future was a just and proportionate response to the non-disclosure.