Build Electronic Documents Questionnaire (PD31B EDQ)
Skill: Assemble a case ESI inventory into a completed PD31B EDQ
Region: United Kingdom Category: Legal / eDiscovery Does: Takes a party's inventory of electronically stored information (ESI) and assembles the completed Electronic Documents Questionnaire in the form annexed to CPR Practice Direction 31B, describing the documents, sources, custodians, and proposed search and disclosure approach. Spec: CPR Practice Direction 31B — Electronic Documents Questionnaire (the form annexed to PD31B)
The EDQ is exchanged in larger cases to inform discussion of electronic disclosure. Section/field names below follow the PD31B questionnaire, not a verbatim schema.
When this applies
- Multi-track cases (typically outside the Business & Property Courts disclosure pilot/PD57AD) where the parties must address electronic disclosure under CPR 31.
- Ordered or agreed to be completed and served, usually not less than 14 days before the first Case Management Conference.
- Must be verified by a statement of truth signed by a person with knowledge of the ESI.
Structure (ESI inventory → EDQ sections)
Section 1 — Scope and extent of the search proposed
date ranges, custodians, document types, keyword/concept searches
Section 2 — Data sources
per source: type (email, file share, mobile, cloud, backup),
custodian, approx. volume, format, accessibility/cost
Section 3 — Preservation
steps taken to preserve ESI; deleted/overwritten data
Section 4 — Tools and formats
review platform, de-duplication, proposed exchange format (native/TIFF/load file)
Section 5 — Difficulties / disproportionality
Statement of Truth (signed, dated)
Data rules
- Proportionality — searches and sources framed against CPR 31.7 reasonable-search / proportionality factors (value, complexity, significance).
- Custodians and sources — each data source tied to named custodians, locations and approximate volumes.
- Exchange format — proposed disclosure format (native + metadata, or image + load file) stated and ideally agreed.
- Identifiers — claim number, parties, court; consistency with the case statements.
- Statement of truth — current CPR wording; signatory and date completed.
Worked example (outline)
Claim no. BL-2026-000123, Claimant Acme Ltd v Beta plc
Search scope: 01/01/2023–31/12/2025; 4 custodians; keywords (12 terms)
Sources: Exchange mailboxes (~80 GB), shared drive (~40 GB), 2 laptops
Preservation: legal hold issued 2026-02; backups suspended
Format: native + extracted text + standard load file
Statement of Truth signed by Head of Legal, 2026-06-01
Served on the other party and filed ahead of the CMC.
Validation checklist
- All data sources and custodians listed with volumes/formats
- Search scope (dates, keywords, types) stated and proportionate
- Preservation steps described
- Proposed exchange format specified
- Claim number / parties consistent
- Statement of truth signed and dated
- Completed/served per the CMC timetable (≈14 days before)
Last updated: 2026-06-04 — confirm the current form, CPR PD31B wording, and timetable against current authority (justice.gov.uk, CPR Part 31 / PD31B) guidance before use.