Vol 23 (2026) - Issue 3

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Webb v Eversholt Rail Limited [2026] EWHC 101 (Ch)

Synopsis
This High Court decision is important for applications seeking information and documents under sections 235 and 236 of the Insolvency Act 1986 (the 'IA 1986'). It considers whether, and when, an office-holder can obtain an order requiring a third party to produce all documents relating to a company regardless of date or subject matter, described as an 'everything forever' application.
The conclusion is, in very short summary: an 'everything forever' order may be available in principle but only if it is 'reasonably required', which a liquidator can likely only demonstrate in unusual circumstances.
They could not do so here. The judgment emphasises the importance of justifying the breadth of documents sought when seeking relief under sections 235 and 236.