You are replying to a demand, complying with something you dispute, or writing up a conversation.
Three phrases you can use exactly, and the habit of confirming every spoken exchange in writing the same day.
A civil litigation solicitor with a professional conduct practice.
The central rule
The record is built from what was said at the time. A sentence written today reads as a plain statement. The same sentence written in a submission a year on reads as a party trying to improve its position. Say the helpful thing when nobody is arguing about it.
The three sentences
- "I am not refusing to comply." Use it when you dispute a demand but are doing, or will do, what an order or rule actually requires. It separates disagreement from defiance; it does not stay the order or extend the time. Without it, a letter that argues can be described later as a refusal, and refusal is a word courts take seriously. Pair it with what you are doing and by when.
- "This is without admissions." Use it when you take a practical step, hand something over, or agree to a process, and you do not want the step read as accepting the other side's version. It records that doing the thing is not agreeing with the reason you were asked. The labels guide explains its limits: the words help; the substance still governs.
- "Subject to any corrections you may have." Use it at the end of a same-day note recording a conversation. It invites them to disagree now, in writing, and it makes silence meaningful. A note that was never corrected is a strong record of what was said: persuasive, not conclusive.
Each phrase goes in the same sentence as the thing it qualifies, not in a separate paragraph. The limited consent guide explains why.
Same-day confirmation
A room where everyone nodded becomes, in writing a week later, "our client was taking instructions". The best protection is a short open email sent the same day, before anyone else's version exists, for procedural conversations. Settlement and mediation discussions are different: they may be protected, and putting them in an open email can compromise that.
- Date and time of the conversation, who was present, and the medium.
- What was agreed, numbered, in plain words, with any limits stated inside each item.
- What was not agreed or was left open.
- "Subject to any corrections you may have." Add "If I do not hear from you by [date], I will proceed on this basis" only where you are independently entitled to proceed; silence is not their agreement.
Five lines is normal. The example letters have a template; the correspondence log is where it is filed. If they reply with a different account, you now have both versions dated the same day, which is a far better position than one version dated later.
From Jordan's case file
Checklist
- Disputed demand: "not refusing to comply" stated with what you are doing and by when
- Practical step taken under protest: "without admissions" in the same sentence
- Every conversation confirmed in writing the same day, "subject to any corrections"
- Limits stated inside each numbered item, not in a separate paragraph
- Confirmation filed in the correspondence log with any reply beside it