Specialists International
This Knowledge Check tests the Technology and Construction Court's decision in Lloyds Developments Limited v Accor Hotel Services UK Limited [2026] EWHC 1522 (TCC). Lloyds sought orders requiring its former directors to provide mobile devices to an independent reviewer for a supervised disclosure exercise.
The applications arose within a deceit claim exceeding GBP 180 million concerning a proposed hotel development. Earlier disclosure orders had not produced effective access to the devices, and separate Part 8 proceedings were issued against the directors.
Mr Justice Constable held that Lloyds had common law and contractual rights to access the devices. The court granted final mandatory relief, found that CPR 31.17 would also have supported the order, and imposed the primary costs liability on the directors.
- The main proceedings and the mobile-device applications
- The earlier disclosure orders and independent reviewer
- The common law rights of a principal against former agents
- Privacy, deleted messages and proportionality
- The directors' obligations under the Funding Agreement
- Final mandatory injunctive relief
- Third-party disclosure under CPR 31.17
- The costs orders made against the directors and Lloyds