• it is normally reasonable for a person submitting a form by electronic mail to expect delivery within a short time thereafter, likely within the hour;
  
• previous case law authorities relating to the ordinary course of post apply also to "the ordinary course of e-mail", including in particular the "Consignia test of objective reasonable expectation" (see Consignia plc v Sealy CA 2002 ICR 1193, CA);
  
• the proposition that it does not matter, in considering whether an extension of time should be allowed to a claimant who has submitted a claim form out of time, why he waited until the last moment to present the complaint is wrong as a free-standing general proposition.

An example of:

• extension of time being granted when a claim form submitted by e-mail did not arrive and the replacement form was submitted less than a week out of time.

For relevant general notes go to Time-limits/extension of time-limits .