In personal injury cases where the plaintiff is unable to produce any eyewitness evidence and the relevant facts are wholly within the defendant's knowledge, interrogatories will generally be 'necessary' within the meaning of District Court Rules Pt 22A r 5(2). The availability of an exculpatory police statement and the theoretical availability of res ipsa loquitur do not render interrogatories unnecessary. Fishing interrogatories are permissible where the area of factual inquiry is wholly or substantially within the defendant's knowledge.
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