PRE TRIAL QUESTIONARE (Order 11, rule 2)

QUESTION ANSWER
(TICK ONE)

1. Identify the relevant track for the case YES NO

2. Have you or your advocate made contact with the
other party of parties in these proceedings with a
view to settling the case or to narrow down the issues YES NO
3. Have given full disclosure of documents to the other party
or parties YES NO
4. If not within what period can disclosure be given? YES NO
5. Is there need for inspection of any documents or
copies thereof and is so how soon can you do the
inspection? YES NO
6. Is there need to serve interrogatories and if so have you
specified the necessary interrogatories. YES NO
7. If defendant, have you answered the interrogatories by
attaching the questionnaire and affidavit with the answer? YES NO
8. Have you filed and exchanged all witness ‘statements? YES NO
9. Have you identified any issues which require a
written report of an expert? YES NO
10. Have you agreed on a single expert to prepare joint report? YES NO
11. If the answer to question 10 is in the negative do you
require directions relating to the payment of the
expert’s fee and expenses? YES NO
12. In which disciplines do you require an expert? YES NO
13. Have the experts agreed on their respective reports? If not
have they held without prejudice discussions in order to
narrow down the issues with a summary of the reasons for any
disagreements? YES NO
14. Have you filed and served an updated schedule of loss and
damage including future loss and if
defendant, have you filed and served a counter schedule YES NO
15. Have you filed this questionnaire together with the answer
including the experts’ joint statement of issues including
witness statements? YES NO
16. Have you considered whether oral evidence of any witness
can be dispensed with? YES NO
17. Have you so far discharged your duty of co-operating with
the other party or parties in preparing the case expeditiously
including attempting to limit the issues in dispute? YES NO
18. Are you aware that you are under an obligations to inform
the court immediately if the case is settled? YES NO
19. Have you prepared a bundle documents for trial
together with a case summary? YES NO
20. Are you aware that you have an obligation to file and serve
any skeleton argument to be used in the case of list 3 days
before the hearing date day? YES NO