CPR PART 35 COMPLIANT EXPERT REPORTS — HARLEY STREET
Expert Reports That Survive Challenge
Most expert reports fail not on the quality of the clinical opinion, but on structure, impartiality, and compliance. Professor Sandip Hindocha is formally trained in CPR Part 35 obligations and writes every report with the overriding duty to the court — not the instructing party — front and centre. The result is an opinion that opposing counsel cannot shake, because it was never written for your side to begin with.
500+
Part 35 Reports Delivered
0%
Reports Rejected for Non-Compliance
48hr
Urgent Turnaround Available
20+
Years Active Clinical Practice
THE LEGAL FRAMEWORK
What CPR Part 35 Actually Requires
The rules are more demanding than most solicitors realise. Every Part 35 report must satisfy six core requirements — and failure on any one of them risks the report being disregarded by the court.
Overriding Duty to the Court
The expert’s duty is to the court, not the party paying the fee. This overrides any obligation to the instructing solicitor. Every opinion in a Part 35 report must reflect the expert’s genuine view — not the view most helpful to the client’s case.
Statement of Truth
Every compliant report must contain a statement that the expert understands and has complied with their duty to the court, and that the contents represent their true and complete professional opinion. Missing or incorrectly worded, this alone can invalidate the report.
Qualifications & Expertise Boundary
The report must state the expert’s qualifications and must not stray beyond their area of expertise. Professor Hindocha confines every opinion to plastic and reconstructive surgery — the field in which he has 20+ years of active NHS and Harley Street practice.
Range of Opinion
Where there is a range of professional opinion on a clinical question, Part 35 requires the expert to summarise that range and explain where their own opinion sits within it. Professor Hindocha’s reports address this with transparency — never suppressing a competing view.
Summary of Instructions
The report must contain a summary of the instructions received. This is not merely administrative — it defines the questions the expert was asked to address and anchors the court’s understanding of the opinion’s scope. Every report from Harley Street Legal states this explicitly.
Material Changes & New Evidence
The expert has a continuing duty to inform the court if they change their opinion after delivery of the report. Where new medical evidence emerges, Professor Hindocha will notify instructing solicitors promptly — and, where necessary, file a supplementary report.
CROSS-EXAMINATION READINESS
What Opposing Counsel Will Look For
Experienced defence counsel will probe four areas in every expert report. Professor Hindocha’s reports are structured to close each line of attack before it is opened.
CHALLENGE
Lack of Independence
Counsel argues the expert advocated for their client, cited only evidence that supported their position, or softened their view after pressure from the instructing solicitor.
HOW WE ADDRESS IT
Every report includes an explicit statement of independence. Professor Hindocha forms his opinion on the evidence alone and will not alter a conclusion simply because it is inconvenient to the instructing party.
CHALLENGE
Outside Area of Expertise
Counsel argues the expert opined on a clinical area outside their specialism, or lacked sufficient recent experience with the procedure at issue in the claim.
HOW WE ADDRESS IT
Professor Hindocha holds FRCS(Plast) and maintains an active NHS consultant and Harley Street practice. His qualifications, GMC specialist registration, and current caseload are documented at the opening of every report.
CHALLENGE
Opinion Without Reasoning
A conclusion stated without explicit reasoning is easily attacked in cross-examination. Counsel asks the expert to justify each step — and the gap in logic is exposed.
HOW WE ADDRESS IT
Every conclusion in a Professor Hindocha report is preceded by the clinical reasoning that supports it. The report is written to withstand the question ‘why?’ at every step — because that question will be asked at trial.
CHALLENGE
Incomplete Evidence Review
Counsel argues the expert formed their opinion without reviewing the complete clinical record, making it partial and unreliable as a foundation for any finding of the court.
HOW WE ADDRESS IT
Every report documents the materials reviewed. Where records are incomplete, this is stated alongside the impact on the opinion. Judges trust an expert who acknowledges limits over one who claims none exist.
JOINT INSTRUCTIONS
Single Joint Experts & Joint Discussions
In lower-value claims, the court may direct the parties to instruct a single joint expert (SJE) rather than each appointing their own. Professor Hindocha accepts SJE appointments and handles all correspondence with both parties transparently — both sides receive every communication and response simultaneously.
Where two party-appointed experts are required to produce a joint statement under CPR 35.12, Professor Hindocha is experienced in expert discussion processes. He approaches these discussions methodically — identifying genuine areas of agreement, clearly delineating where opinions differ and giving clear reasons for each divergence. The result is a joint statement that helps the court understand precisely where the experts agree and where they do not, rather than papering over real disagreement.
Party-Appointed Expert
Instructed by one party. Opines on the questions put by that party’s solicitor. Must still comply with CPR 35 and maintain independence. Both claimant and defendant solicitors may instruct. A joint statement may be required if the opposing expert disagrees.
Single Joint Expert (SJE)
Instructed by both parties jointly, often at court direction. Questions may be put by both sides. All correspondence is shared. The SJE’s report stands alone — there is no competing expert. Typically used in lower-value claims to control costs.
Expert Discussion & Joint Statement
Where both parties have appointed experts, the court may direct a without-prejudice discussion to produce a joint statement. The statement identifies agreed issues and those still in dispute. The court uses it to narrow the issues for trial.
CPR PART 35 — YOUR QUESTIONS
Frequently asked questions.
Yes. A report drafted to the CPR Part 35 standard is equally effective in pre-litigation settlement discussions. Defendants and their insurers recognise a fully compliant report — and know that if the matter proceeds to court, it will be difficult to challenge. Many cases settle once a robust expert report is served, without proceedings ever being issued.
A desktop review is based solely on the medical records, imaging, and documentation provided — no examination of the claimant is carried out. A full report involves examination and is appropriate where the current extent of scarring, functional loss, or physical condition is central to quantum. We will advise you on which is appropriate for your case at the point of instruction.
Professor Hindocha is available to give oral evidence at trial when required. His reports are structured with trial evidence in mind — every conclusion is supported by explicit reasoning, meaning cross-examination attempts to undermine the report’s logic tend to backfire. We have extensive experience of oral evidence in both county and High Court proceedings.
Standard turnaround is 10–15 working days from receipt of a complete instruction pack. Urgent instructions requiring desktop reviews within 48 hours are accepted subject to availability — call us directly to confirm. Examination appointments at Harley Street are typically available within 5–7 working days.
Yes. Where the court directs an expert discussion under CPR 35.12, Professor Hindocha attends and engages constructively with the opposing expert. He approaches the discussion with the same objectivity as the original report — to identify genuine agreement where it exists and to articulate clearly, with reasons, where it does not.
WHAT SOLICITORS SAY
Reports That Win Arguments
“I’ve served a lot of expert reports over the years. Professor Hindocha’s are the ones that opposing solicitors don’t bother challenging. The reasoning is too thorough, the independence too obvious.”
A. Morrison
Senior Partner, Personal Injury
“We used Professor Hindocha as an SJE in a disputed scarring claim. Both parties accepted his conclusions. The matter settled on the steps of court for a figure we were very happy with. Exactly what a good SJE should achieve.”
R. Okafor
Solicitor, Claimant Personal Injury
“His report on a clinical negligence claim involving reconstructive surgery complications was the clearest I’ve read. The range-of-opinion section alone was worth the instruction fee — it directly addressed the defendant’s expert’s position before we’d even seen their report.”
D. Whitfield
Associate, Clinical Negligence
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