28 sub-arguments supporting the 19 grounds of voidness. Each is a specific legal proposition with its own evidence chain.
SUB-G1-1
The Breathing Space Timeline
The Moratorium commenced 28.12.2024. Orders were sealed on Days 9, 39, 40, and 61 of the 110-day window. All contain enforcement elements (costs, unless terms) and are void under Reg 7(12).
SUB-G1-2
Reg 7(12) Zero Discretion
Regulation 7(12) provides 'shall be null and void'. It leaves no room for discretion. The court was on actual notice from 29.12.2024 (email receipt) yet proceeded to seal orders.
SUB-G1-3
The CLCC Jurisdiction Trap (PE Transfer)
Proceedings under IA 1986 Parts 1-7 (Winding Up) cannot be transferred to Central London County Court per SI 2014/817. The Transfer Order of 23.07.2025 cited the wrong statutes (Bankruptcy sections) to force the transfer.
SUB-G2-1
The Smoking Gun (Ruling Para 41)
Master Kaye's ruling at Para 41 expressly cites the 20.02.2025 complaint as evidence of 'persistence' justifying the LCRO. This weaponises the complaint mechanism, creating a circular trap where complaining about bias triggers restraint.
SUB-G2-2
Potanina Violation (Rule One)
The 27.02.2025 cluster of orders was made ex parte without notice. Lord Leggatt's 'Rule One' (Potanina) requires that a party must have a fair chance to object before an order is made. No CPR 3.3(5) notice was visible.
SUB-G2-3
N460 Procedural Invention
The N460 dated 27.02.2025 claims to refuse permission to appeal. No appellant's notice (N161) was ever filed. The court invented an application to refuse it, solely to apply a TWM certification.
SUB-G3-1
Specific Default Counts
BL-2024-001089: 540+ days (served 01.08.24). BL-2024-001166: Defence filed 27 days late with no CPR 3.9 relief, is 'of no effect' (Billington). BL-2025-000147: stayed pre-service (void stay).
SUB-G3-2
Admissions of Liability (Defence)
Defence Para 10.5.2 admits 'six lockouts without notice'. Defence Para 17.4 admits 'no adjustments were made'. These are formal admissions binding under CPR 14.
SUB-G3-3
Harassment Warning Ignored
The Claimant issued a written warning on 17.02.23 stating 'I will report you to police'. Two further lockouts (27.04.23 and 20.05.23) occurred AFTER this warning, proving 'course of conduct' (Majrowski).
SUB-G4-1
PD 1A Systematic Denial
Despite disclosed ADHD/ASD diagnoses and RA reference on file, no PD 1A adjustments were ever offered or considered across 28 judicial events.
SUB-G4-2
Galo v Bombardier Application
Wholesale failure to make reasonable adjustments requires proceedings to be set aside (Galo v Bombardier [2016] NICA 25).
SUB-G5-1
Multi-Limb TWM Error
The 03.02.2025 application had 11 limbs, including administrative housekeeping (transcripts, consolidation) which were plainly capable of success. Applying a global TWM to the whole application violates Wasif/Grace.
SUB-G5-2
N460 Jurisdictional Invention
The N460 dated 27.02.2025 refused 'Permission to Appeal' when no PTA application (Form N161) was ever filed. The court unilaterally 'deemed' Part 3 submissions to be a PTA application to refuse them with TWM.
SUB-G5-3
Equitable Assignment (s.130(2))
The s.130(2) refusal ignored the Equitable Assignment of 26.04.2024 (Particulars para 10.2.1), which transferred claims to the Applicant personally, arguably rendering s.130(2) leave unnecessary. This was an arguable point, not TWM.
SUB-G6-1
MHCM Conflict with Unless Order
The £12,000 unless order of 06.02.2025 (Day 40 of MHCM) requires payment enforcement which is expressly prohibited under Reg 7(5). The condition itself is void.
SUB-G6-2
Financial Impossibility
The court had notice of winding-up (25.09.2024) and MHCM (29.12.2024). Imposing £12k payment on someone in insolvency and mental health crisis is manifestly disproportionate.
SUB-G7-1
Excelsior Standard Not Met
Indemnity costs require conduct 'out of the norm' (Excelsior). The Claimant's conduct was consistent with a litigant in person exercising their right of access to justice during MHCM.
SUB-G8-1
10 Void Orders During MHCM
Ten orders were sealed between 06.01.2025 and 16.04.2025 (MHCM period). All contain enforcement elements and are void ab initio under Reg 7(12). These include the LCRO, unless order, costs orders, and TWM certifications.
SUB-G9-1
7-Day Complaint Nexus
The LCRO was imposed exactly 7 days after the formal complaint of 20.02.2025. The ruling at Para 41 expressly references this complaint as justification.
SUB-G9-2
No CPR 3.11 Warning
CPR 3.11 requires a warning before any CRO. No such warning was ever given. The court jumped directly to LCRO without the mandatory preliminary step.
SUB-G9-3
TWM Count Incorrect
PD 3C requires 'three or more' TWM certifications. The N460 (27.02.2025) was the third, but it refused a non-existent application. Properly counted, only two valid TWMs existed.
SUB-G9-4
No Lesser Sanctions Considered
The court did not consider any lesser sanctions (costs warning, extended CRO). The LCRO was the nuclear option applied without proportionality analysis.
SUB-G10-1
540-Day Default (R1)
Chelsea Harbour Ltd has been in default since service on 01.08.2024. As of today, this exceeds 540 days. CPR 12.3(1) mandates judgment entry.
SUB-G10-2
Six Admitted Lockouts
Defence Para 10.5.2 admits 'six lockouts without notice' between October 2022 and May 2023. This admission is binding under CPR 14.
SUB-G10-3
No Reasonable Adjustments Admitted
Defence Para 17.4 admits 'no adjustments were made' for the Claimant's disability. This is an admission of EA 2010 s.20 breach.
SUB-G10-4
Abuse of Process by R1
The defendant's strategy of avoiding service, filing no defence, and benefiting from court orders made during MHCM constitutes abuse of process.
SUB-G10-5
No Real Prospect of Defence
Given the formal admissions (lockouts, no adjustments) and 540-day default, the defendant has no real prospect of successfully defending the claim. Summary judgment is appropriate.
SUB-G11-1
Cumulative Effect Analysis
The totality of procedural irregularities (29:0 bias, MHCM void orders, PD 1A denial, complaint weaponisation, TWM clustering) renders the proceedings fundamentally unfair under Article 6 ECHR.