What is the key principle from Bale v Mills about submitting material after a hearing?

• A. Parties may file additional material with the court after a hearing if they have leave.
• B. The court must ignore any further submissions regardless of leave.
• C. Parties should not place before the court any further material after a hearing without leave.
• D. Submissions after reserved matter can be made if related to Browne v Dunn.

Answer: (C)

The key idea is that after a hearing has taken place, you should not introduce any new material to the court without obtaining leave. Bale v Mills sits behind this rule, emphasizing that the record should not be expanded with late submissions unless the judge explicitly allows it. This keeps the process fair and orderly: once the hearing is finished, the court’s attention is on the material already before it, and any fresh material could disrupt the balance between the parties or surprise the other side. If the court grants leave, late material can be admitted and considered, but without such permission it should not be placed before the court.