This decision by Burton J gives a good indication of the very wide impact of CPR 3.9. Burton J said,

“85.I am accordingly considering CPR Rule 3.9 but …also Rule 13.3… I am satisfied…that the new approach described by Lord Dyson’s Implementation Lecture and exemplified in Mitchell is intended to be of universal effect, i.e. across the board in relation to the CPR, by reference at least to the amended Overriding Objective.”