3. What documents do the parties need to prepare for the hearing of the interlocutory application?

3. What documents do the parties need to prepare for the hearing of the interlocutory application?

Unless otherwise directed by the Court, the applicant should serve on the other party / parties and lodge with the Court the hearing bundles and his skeleton argument and list of authorities at least 72 hours before the hearing (excluding Saturdays, Sundays and general holidays).

The respondent should serve on the other party and lodge with the Court his skeleton argument and list of authorities at least 48 hours before the hearing (excluding Saturdays, Sundays and general holidays).

Hearing bundles for interlocutory applications

For any contested interlocutory applications listed for more than 30 minutes, the applicant of such application has the duty to prepare the paginated Hearing Bundles for use in the hearing. 

The Hearing Bundle shall usually contain the following documents:-

1. Copies of the court documents (pleadings, summons, order for directions, affidavits / affirmations, etc.) relevant to the particular application;
2. Copies of the exhibits relevant to the particular application; and
3. Copies of inter partes correspondences relevant to the particular application or appeal (if any).

Skeleton arguments for interlocutory applications

Skeleton argument is a concise and succinct document which states all the points which a party intends to take and summarize the argument on each of those points.  A point not taken or an argument not advanced in a party's skeleton argument may not be pursued at the hearing of the application without the leave of the Court.

According to Practice Directions 5.4 issued by the Judiciary, a skeleton argument should outline:

(1)   the order sought from the Court;

(2)   the grounds upon which the order is sought;

(3)   the authorities to be cited with references to passages relied upon (if any);

(4)   the evidence/documents relied with cross referenced to the Hearing Bundles; and

(5)   the points of fact, law and procedure to be taken and the arguments on each of such point.

Similar with the Hearing Bundles, unless otherwise directed by the Court, the applicant should serve on the other party / parties and lodge with the Court the hearing bundles at least 72 hours before the hearing (excluding Saturdays, Sundays and general holidays).