1Under RSC O 36B r 2(2D), the wider the scope of a subpoena sought in proceedings requiring exceptional circumstances for leave, the less likely it is that the circumstances will be sufficiently exceptional to justify the grant of leave.
2A company having been wound up when it should not have been is capable of constituting 'exceptional circumstances' justifying the grant of leave to issue a subpoena in support of a reinstatement application.
3Where essentially the same documents are sought from two recipients, the court may confine the subpoena to a single recipient where that is sufficient to achieve the legitimate forensic purpose.
