Recommended reading: Pleadings Without Tears – A guide to legal drafting under the Civil Procedure Rules by William M Rose, Blackstone Press Limited (5th edition, 1990)
Pleading in the alternative: Binks v Securicor Omega Express Ltd [2003] EWCA Civ 993
https://www.bailii.org/ew/cases/EWCA/Civ/2003/993.html
https://swarb.co.uk/binks-v-securicor-omega-express-ltd-CA-16-Jul-2003
Importance of pleading facts clearly:
LIMITS ON THE DUTY OF COUNSEL TO ADVISE ON COSTS AND FUNDING: ALSO PARTICULARS OF CLAIM – IF YOU CAN’T PLEAD A CASE PROPERLY ITS PROBABLY INDICATIVE OF A POOR CASE
Pete's Library 