The English Civil Procedure Rules specify a number of “jurisdictional gateways” by which a foreign defendant may be brought within the jurisdiction of the English courts under the so-called common law rules. Amongst these is the “necessary or proper party” gateway. This requires all of the following:

• A claim against a defendant (the so-called “anchor defendant”) on whom the claim form has been or will be served — otherwise than in reliance on this gateway (this requires underlying proceedings to which the foreign defendant is to be added)

• A real issue between the claimant and the defendant that is reasonable for the court to try

• That the claimant wishes to serve the claim form on another person who is a necessary or proper party to that claim