The N244 application includes three draft orders designed to prevent the Defendants from restarting the costs cycle that has been used to block access to justice:
The Applicant shall not be liable for the Respondents' costs in these proceedings. The Applicant is a litigant in person with ADHD and ASD, facing three corporate defendants with commercial legal teams. The public interest in the declarations of voidness justifies a protective costs order.
No further stay of proceedings on costs grounds shall be imposed without an oral hearing at which the Applicant has the opportunity to make representations, and a reasonable adjustment assessment under EA 2010 s.20.
Using costs orders to block a disabled litigant from accessing the court constitutes discrimination arising from disability under EA 2010 s.15. The Respondents shall not make any further application to stay or strike out on the basis of unpaid costs where the costs orders are themselves void or where the Applicant's inability to pay arises from disability-related circumstances.