Can the court permit service of an injunction on a person outside the jurisdiction who is not defendant to any substantive cause of action? In Gilbert v Broadoak,1 David Quest KC (sitting as a Deputy High Court Judge) concluded it could not. In doing so, he offered the first authoritative ruling on a topic of recent judicial speculation: whether s.37(1) of the Senior Courts Act 1981 (“SCA 1981”) permits service out of an injunction even if there is no other basis for so doing. His decision was correct, and—as the point appears to be headed to the Court of Appeal—it should be upheld.

The first claimant had made loans to the defendant (Broadoak) through the second claimant.2 Those loans had not been repaid, and in 2025 the claimants obtained an English