England and Wales · Civil Procedure Rules
When is the return hearing after a without-notice freezing order?
Read the return date in the freezing order. Current CPR 25.9 requires a return date for a without-notice interim injunction unless the court orders otherwise. It does not establish one automatic fourteen-day hearing date.
- Period
- The return date and compliance dates in the order
- Trigger
- The actual return hearing fixed by the court
- Rule
- CPR 25.9(3), 25.12 and 25.14
The source comparison uses CPR 25.9(3), 25.12 and 25.14. A freezing order’s return hearing is distinct from application issue, prompt post-order service and any specific evidence direction.
Source guide · No automated date
Check the applicable procedure
The current Part 25 and approved model order govern the injunction. A without-notice order date alone cannot establish its return hearing or evidence timetable. The approved freezing model wording must be used with modifications identified under rule 25.14.
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When is the return hearing after a without-notice freezing order?
Read the return date in the freezing order. Current CPR 25.9 requires a return date for a without-notice interim injunction unless the court orders otherwise. It does not establish one automatic fourteen-day hearing date.
Responsible actor. The applicant complying with the freezing order and its undertakings.
The actual return hearing fixed by the court
Rule 25.9(3)(c) ordinarily requires a return date where the injunction was made without notice.
The current Part 25 and approved model order govern the injunction. A without-notice order date alone cannot establish its return hearing or evidence timetable.
CPR 25.9(3), 25.12 and 25.14How does this provision count time?
- Take the hearing date from the actual order. Count any separately directed evidence or service period from the event that the order identifies.
- The approved freezing model wording must be used with modifications identified under rule 25.14.
Take the hearing date from the actual order. Count any separately directed evidence or service period from the event that the order identifies.
A court closure does not allow the user to substitute another listed return hearing. Obtain the actual listing or further order.
CPR 25.9(3), 25.12 and 25.14Which facts prevent one automatic date?
The current Part 25 and approved model order govern the injunction. A without-notice order date alone cannot establish its return hearing or evidence timetable. The approved freezing model wording must be used with modifications identified under rule 25.14.
An October 9, 2026 freezing order fixes a return hearing for October 16. The listed date controls; a fourteen-day placeholder would produce a different date. Attend and comply with the actual return hearing order.
A user suspects the listed return date conflicts with a closure. A generic calculator cannot change the court’s listing. Confirm the hearing arrangements with the actual order and court.
The court makes a different direction about the return hearing or service. Part 25 preserves the actual order and required undertakings. Read the modified order instead of assuming the ordinary model terms.
Which conditions and exceptions apply?
- Applicable procedure
- Rule 25.9(3)(c) ordinarily requires a return date where the injunction was made without notice.
- Material qualification
- The approved freezing model wording must be used with modifications identified under rule 25.14.
- Completion and variation
- Current Part 25 replaces the legacy reliance on omitted PD 25A; historical orders need their own edition check.
- The current Part 25 and approved model order govern the injunction. A without-notice order date alone cannot establish its return hearing or evidence timetable.
- A freezing order’s return hearing is distinct from application issue, prompt post-order service and any specific evidence direction.
What must the responsible actor complete?
Questions about this procedure
When is the return hearing after a without-notice freezing order?
Is the freezing order return date always fourteen days later?
No. Read the date that the court fixed in its order. Current Part 25 supplies no universal arithmetic return date.
CPR 25.9(3), 25.12 and 25.14Must a without-notice injunction contain a return date?
Rule 25.9(3)(c) ordinarily requires one unless the court orders otherwise.
CPR 25.9(3), 25.12 and 25.14Which freezing order wording should the applicant use?
Rule 25.14 requires the approved model wording, modified as appropriate. The modifications must be drawn to the judge’s attention.
CPR 25.9(3), 25.12 and 25.14What must be served after a without-notice injunction?
Rule 25.9(3)(b) ordinarily requires an undertaking to serve the application, supporting evidence, hearing note and order as soon as practicable.
CPR 25.9(3), 25.12 and 25.14Does the return hearing fix every evidence deadline?
No. Read the actual order and applicable procedural requirements for each document and recipient.
CPR 25.9(3), 25.12 and 25.14Can a closed court day automatically move the return hearing?
No. A listed hearing requires the actual court listing or further direction. Do not replace it with a generic office rollover.
CPR 25.9(3), 25.12 and 25.14Official sources and review
Provisions used (2)
| Provision | Purpose |
|---|---|
| CPR 25.9(3), 25.12 and 25.14 | Check the identified procedure, event, counting rule or qualification |
| CPR 2.8 and 2.9 | Check the identified procedure, event, counting rule or qualification |