Tian v Refinitiv Limited: High Court refuses anonymity and dismisses World-Check claim for service failures

The High Court has dismissed a Norwich Pharmacal claim brought by a Chinese national seeking to identify those responsible for his entry on the World-Check database, after ruling both that anonymity was unwarranted and that the claim form had never been validly served.

In Tian v Refinitiv Limited [2026] EWHC 1418 (KB), DHCJ Guy Vassall-Adams KC refused the claimant's applications for a private hearing and anonymity, and upheld the defendant's jurisdiction challenge on the basis that the claimant had allowed the four-month service deadline under CPR 7.5 to expire without taking any steps to serve the claim form.

The privacy applications

Wenjun Tian, who is identified in a public Administrative Court judgement relating to a National Crime Agency disclosure order, sought to challenge his entry on the World-Check database, a subscription-based database of politically exposed persons and individuals considered high risk for corruption, fraud, and money laundering. He applied for a private hearing, anonymity, and restrictions on access to the court file, citing risks to his physical safety and reputational harm.

Vassall-Adams KC rejected both the private hearing and anonymity applications, applying the established open justice principles summarised in Practice Guidance (Interim Non-Disclosure Orders) [2012] 1 WLR 1003. The court found that no exceptional circumstances existed justifying departure from the open justice principle and that the claimant had not provided clear and cogent evidence that his identification would create any objectively founded risk to his physical safety.

On the question of reputation, the court held that Article 8 reputational interests are not a trump card in the context of court proceedings and that open justice, Article 6, and Article 10 rights ordinarily prevail. Crucially, the claimant's name and the underlying allegations of fraud were already extensively in the public domain, including through a public Administrative Court judgement and widespread UK and international media reporting concerning the forfeiture of two Hampstead properties following a settlement with the NCA. The only concession made was a limited order redacting the claimant's home address from any documents made available from the court file.

The jurisdiction application

The substantive issue turned on the claimant's failure to serve the claim form within the four-month period prescribed by CPR 7.5. The claim form was issued on 30 May 2025. The claimant took no steps to serve it before the 30 September 2025 deadline, apparently intending to pursue his Norwich Pharmacal application without notice to the defendant. The defendant first learned of the proceedings on 27 October 2025, after the deadline had already passed, and Refinitiv's solicitors made clear upon receiving documents by email on 6 November 2025 that no formal service had taken place.

The court disposed of several attempted routes to rescue the claim. An application under CPR 7.6 for an extension of time had never been made and, in any event, the claimant had taken no steps whatsoever to effect service, failing the requirement to have taken "all reasonable steps". The court held that CPR 6.15, which permits service by an alternative method, had no application to the retrospective validation of a claim form served out of time; that power existed exclusively under CPR 7.6. The court further held, applying Godwin v Swindon Borough Council [2002] 1 WLR 997, that CPR 6.16's power to dispense with service in exceptional circumstances could not be invoked to circumvent the strict requirements of CPR 7.6(3), and that no exceptional circumstances existed in any event.

The court also addressed the defendant's failure to file an acknowledgment of service before challenging jurisdiction, holding that no such obligation arises where a claim form has never been validly served, following the Court of Appeal's recent decisions in Robertson v Google LLC [2025] EWCA Civ 1262 and Bellway Homes Limited [2025] EWCA Civ 1347.

The claimant's apparent belief that he was entitled to proceed without notice was described as a "misuse of the court's process", there being no risk the defendant could have taken steps to frustrate any eventual order. The jurisdiction application succeeded and judgement was entered for the defendant.