M. D. Eastwood
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Overview & Briefing 4
Judicial Briefing Guide for Court How the Cases Connect The Story
Orders Sought 4
Relief Sought 33 Quantum (£8.2M+ pleaded) Why One Judge Must Hear All Settlement Exposure The Costs Trap
Void Ab Initio 29:0
29 Adverse : 0 Favourable 1 in 537M 21 Void Orders (All Void) MHCM Calendar Defence Admissions Defence Contradictions Equality of Arms Filing Pattern (0/12 RA) Staff Impact (6 Resignations) Gaslighting 13
No Time Bar Applies 9 Grounds
Grounds of Voidness 23
CA-2024-001353 · s.31A SCA 1981
Appeal Overview 23 Grounds of Voidness Argument Map KB Hearing (7 June) Waiver/Estoppel
Judicial Review 12
7 bodies · 34 ECHR · permission sought
JR Targets 7 ECHR Violations 34 Institutional Failures Solicitor Misconduct Transcript Obstruction 0/12 Adjustments Granted Subject Access Requests SAR Tracker 3 overdue Pre-Action Letters Constitutional DWP Judicial Review Wheelchair Ramp
The 6 Cases 6
Chelsea Harbour Ltd (R1) Lower Richmond Properties Ltd & Vista (London) Ltd (R2, R3) Personal Damages Insolvency KB Injunction Defendants

Evidence & Documents 11
103 exhibits · 160 authorities · 1395 events
Evidence Hub Exhibits 103 Gallery Chronology 1395 Authorities 160 Key Quotes Revenue & DCF Costs Analysis OR Response + 15 Enclosures Applications All Documents
Reference & Tools 14
Ask the Case Search / Master Timeline Order Timeline CPR Heatmap CPR Dictionary Citation Index Glossary Evidence Trails Document Timeline Evidence Matrix Evidence Audit Argument Index Data Health Open Justice Assurance and Governance Health Report
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Legal/The Costs Trap

The Costs Trap

How void costs orders are used as a weapon to deny a disabled litigant in person access to justice. The circularity is complete: cannot challenge costs without paying costs, cannot pay costs without income, income destroyed by the forfeiture that the costs were supposed to adjudicate.

Every costs order referenced on this page was made during the MHCM period or on void orders. They are void ab initio under Reg 7(12) DSRR 2020. No costs are lawfully due. The enforcement of void costs against a disabled person receiving LCWRA is itself unlawful.
£34,528 Void Costs Total
3 Void Costs Orders
£9,300 LCWRA Arrears Owed
0/12 RA Requests Granted

The Costs Chain

Three costs orders, each building on the last. Each void. Together they form a financial barrier designed to prevent a litigant in person from accessing justice.

£10,000 VOID (MHCM)
Kelly Hearing (Interim Costs)
Master Kelly · BL-2024-001089 · Interim hearing
Costs ordered at an interim hearing. The Claimant disclosed his ADHD and requested adjustments (Kelly transcript para 50). None were made. The Claimant was told 'had you had counsel maybe you would have won'. The costs from this hearing became the seed from which the entire trap grew.
feeds into
£22,528 VOID (MHCM DAY 9)
DDJ Wood Order (MHCM Day 9)
DDJ Wood · 6 January 2025 · BL-2024-001166 (former County Court ref L10CL352) / BL-2024-001166
Costs at the hearing were 'reserved'. The sealed order contains 'forthwith £22,528'. This is a CPR 40.12 fabricated term. The sealed order also added a strike-out of Mastermind Group Ltd as Second Claimant. This was MHCM Day 9. The court was notified of the MHCM on 29 December 2024. Void ab initio under Reg 7(12).
feeds into
£12,000 VOID (MHCM DAY 40)
Master Kaye Order (MHCM Day 40)
Master Kaye · 6 February 2025 · BL-2024-001089
Stay hearing. Master Kaye acknowledged her daughter has ADHD ('they always leave everything to the very last minute') then imposed a 4-working-day deadline and refused all reasonable adjustments. The same judge who imposed the LCRO 21 days later. The same judge complained about 7 days before the LCRO. MHCM Day 40. Void ab initio.
£34,528
Total void costs. Every penny ordered during the MHCM or on fabricated terms. Zero lawfully due.

The Circular Trap

The costs orders create a closed loop. At each step, the Claimant is trapped by the consequences of the previous step. There is no exit.

1
Costs ordered at interim hearing. The Claimant, a disabled LiP without legal representation, is ordered to pay costs. He cannot afford representation because the defendants' unlawful forfeiture destroyed his business (revenue fell 77.5% from £624,568 to £140,327).
2
Costs become a stay. Master Kaye uses the unpaid costs as justification for staying the Chelsea Harbour proceedings (BL-2024-001089). The stay prevents the Claimant from pursuing his claim. The claim is the route to recovery of the income the defendants destroyed.
3
Stay becomes LCRO. The Claimant's attempts to lift the stay (which prevents him from pursuing his claim) are characterised as 'persistence'. The complaint about the stay is cited at para 41 of the LCRO ruling as evidence of unreasonable behaviour. The LCRO is imposed 7 days after the complaint.
4
LCRO blocks applications. The 2-year LCRO on BL-2024-001089 prevents the Claimant from making applications in the Chancery Division without permission. He cannot challenge the costs. He cannot lift the stay. He cannot pursue the claim.
5
Cannot pay because of the forfeiture. The Claimant cannot pay the costs because his income was destroyed by the defendants' unlawful forfeiture. The forfeiture is the subject of the claim that the costs order is preventing him from pursuing. The circle is complete.
6
DWP sanctions for not paying. The Claimant is on Universal Credit. DWP sanctions flow from inability to comply with requirements imposed by void orders. LCWRA awarded 16 February 2026 proves inability to work and all prior sanctions were unlawful. DWP owes £9,300 in arrears.

The DWP Connection

The costs trap extends beyond the civil courts into the welfare system. The connection establishes that enforcing void costs against a disabled person on benefits is not merely procedurally wrong. It is discriminatory.

LCWRA Awarded 16 February 2026

The DWP's own assessment confirms the Claimant has limited capability for work and work-related activity. This is the highest tier of disability recognition in the benefits system. It proves inability to pay costs. It proves all prior sanctions for non-compliance were unlawful. DWP owes £9,300 in LCWRA arrears.

2-Year WCA Delay

The Work Capability Assessment took 2 years. During those 2 years, the Claimant was treated as fit for work, sanctioned for non-compliance, and subjected to conditions he could not meet because of the disabilities the WCA eventually confirmed. The delay itself is a failure of reasonable adjustment.

Pre-Action Protocol: No Response

Pre-action protocol letter sent to DWP. Deadline expired 5 March 2026 with no response. The DWP has not engaged. Judicial review proceedings are the next step (see JR-5).

Equality Act 2010 Analysis

The costs trap engages multiple provisions of the Equality Act 2010.

Section 15: Unfavourable Treatment Arising from Disability

The Claimant's inability to pay costs arises from his disability (ADHD/ASD causing executive function impairment, inability to manage complex litigation without support, the commercial destruction caused by the defendants' actions which he could not prevent because of his disabilities). Enforcing those costs is unfavourable treatment arising from disability.

Section 20: Failure to Make Reasonable Adjustments

The court's practice of ordering costs against LiPs at interim hearings puts disabled LiPs at a particular disadvantage. The reasonable adjustment would be to consider the disability context before ordering costs, to consider ability to pay, and to consider whether costs orders will deny access to justice. None of this was done. 0/12 adjustment requests granted.

Section 149: Public Sector Equality Duty

The court is a public authority. It must have due regard to the need to eliminate discrimination and advance equality of opportunity. No PSED analysis was conducted before any costs order. No consideration of the Claimant's disability in the costs context. The PSED is proactive. The court had knowledge (Kelly transcript para 50: 'I have ADHD and autism').

Key Authorities

R (UNISON) v Lord Chancellor
[2017] UKSC 51
Principle: Access to justice is a constitutional right. Financial barriers that effectively prevent access to the courts are unlawful. Lord Reed at [66]: 'The right of access to the courts is not, and has never been, for sale.' £34,528 in void costs against a disabled person on LCWRA is a financial barrier to justice.
Coventry v Lawrence (No. 3)
[2015] UKSC 50
Principle: Costs orders must not have a chilling effect on access to justice. Lord Neuberger at [32]: the court must consider whether a costs order will deter a party from pursuing a legitimate claim. The costs trap has not merely chilled access to justice. It has frozen it.
Reg 7(12) DSRR 2020
Debt Respite Scheme (Breathing Space Moratorium and Mental Health Crisis Moratorium) (England and Wales) Regulations 2020
Principle: During a Mental Health Crisis Moratorium, the court 'must not make an order' for enforcement. Costs orders made during this period are void ab initio. Lees v Kaye [2022] EWHC 1151: no discretion. All three costs orders fall within the MHCM period or are derivative of void orders made during it.
Equality Act 2010, s.15
EA 2010
Principle: A person discriminates against a disabled person if they treat the disabled person unfavourably because of something arising in consequence of the disability. The inability to pay costs arises from the disability. Enforcing those costs is unfavourable treatment. The court knew about the disability (Kelly transcript para 50).

The Bottom Line

The costs trap is not a side issue. It is the mechanism by which the court prevents the Claimant from accessing justice.

  1. All three costs orders are void. Made during the MHCM or on fabricated terms. Zero costs are lawfully due.
  2. The circularity is intentional or negligent. Costs create a stay. The stay creates the LCRO. The LCRO prevents challenges. The circle closes.
  3. The Claimant cannot pay. LCWRA confirms inability to work. Revenue destroyed by the defendants' actions. DWP owes £9,300 in arrears.
  4. Enforcing void costs against a disabled person is discriminatory. EA 2010 s.15 (unfavourable treatment), s.20 (no adjustments), s.149 (no PSED).
  5. Access to justice is a constitutional right. R (UNISON) v Lord Chancellor. It is not for sale. £34,528 in void costs is the price tag the court has placed on this Claimant's right to be heard.

Related Pages

19 Grounds of Voidness 21 Void Orders Full Costs Analysis MHCM Calendar 0/12 Adjustments DWP Judicial Review

© 2026 Michael Darius Eastwood.