“The MHCM does not apply to court proceedings. The orders are valid.”
Regulation 7(12) DSRR 2020 prohibits "any steps" to enforce a debt during the moratorium. The Supreme Court has not yet considered whether court orders constitute "steps to enforce." However, Lees v Kaye [2023] EWHC 152 (KB) held that an order for costs forthwith IS enforcement. The costs orders (DDJ Wood: £22,528; Master Kaye: £12,000) are plainly enforcement steps. The LCRO and strike-out are enforcement mechanisms. Even if some orders are not "enforcement," the costs orders certainly are.
“The Claimant waived his right to challenge the County Court jurisdiction by participating in BL-2024-001166 (former County Court ref L10CL352).”
Per Isaacs v Robertson [1985] AC 97, delay or acquiescence does not validate a nullity. A void act is void. It cannot be cured by participation. Furthermore, the Claimant had no choice: his CE-File set-aside application was deleted, and he was told High Court filings would be struck out. Conduct under compulsion is not consent.
“The 29:0 pattern is coincidence. Each decision was correct on its merits.”
Per Essop v Home Office [2017] UKSC 27, statistical disparity speaks for itself. The Respondent does not need to explain WHY. only that the pattern exists. Furthermore, this argument requires defending each decision individually. At least 9 orders are void under statute (not a matter of judicial discretion). The Defence admits liability. One judge fabricated order terms. One judge acknowledged the disability disadvantage then ruled against. These are not matters of legitimate discretion.
“The Claimant is vexatious. The LCRO proves it.”
The LCRO was imposed 7 days after a formal complaint about the same judge (Master Kaye, 20-27 Feb 2025). It was imposed during the MHCM period (MHCM Day 61), making it void ab initio. The predicate TWM certifications are all either void (MHCM) or procedurally defective (misclassified applications, wrong limb). A claimant who has built a 300+ page evidence portal with AI analysis, SHA-256 document integrity, and addresses counter-arguments is demonstrably not vexatious.
“The forfeiture was lawful. Chelsea Harbour exercised peaceable re-entry.”
Peaceable re-entry requires (1) no s.146 notice for non-rent covenants, (2) actual physical re-entry, (3) no waiver. Here: no s.146 notice was served. The "termination" was by email (not post as required by the contract). Chelsea Harbour continued to address the Claimant as "tenant" 10+ times after the alleged forfeiture (waiver: Matthews v Smallwood). The chattels were sold to a competitor after a cease-and-desist letter (conversion). The Defence has not even been filed.
“The reasonable adjustments were not required because the Claimant was competent to litigate.”
The duty to make reasonable adjustments under EA 2010 s.20 is not contingent on the person being unable to litigate. It exists when a disabled person is at a substantial disadvantage compared to a non-disabled person (s.20(3)). The Claimant has ADHD and ASD (confirmed by Dr Woolley). The adjustments requested (breaks, email service, 14-day buffers, structured hearing aids) are standard PD 1A measures. Recorder Cohen KC himself acknowledged: "Had you had counsel maybe you would have won." That is the substantial disadvantage. The duty applies.
The Respondents' best arguments fail because the evidence is structural, not circumstantial. Void orders cannot be defended on their merits. Admitted liability cannot be withdrawn. Statistical impossibility cannot be explained by coincidence. The case stands.