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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Ground JR-17
https://www.michaeldariuseastwood.com/legal
Legal/Grounds/JR-17

JR-17

Article 14 + Article 6 (Discrimination in Fair Trial)

LOCKED MEDIUM Priority
MEDIUM PRIORITY
7/10
Probability
7/10
Impact
49
Priority Score

Cohen 'had you had counsel' remark. But single remark may not suffice alone.

The Applicant was treated differently because of his disability. Recorder Cohen: 'had you had counsel maybe you would have won.' Rather than providing adjustments to level the playing field, the court punished the disability.

Supporting Evidence

Authorities (2)

  • European Convention on Human Rights, Article 14
  • Cam v Turkey (2016) 65 EHRR 32

Exhibits (2)

  • CA-MED-002 Dr Woolley Report (26 Apr 2024)
  • CA-MED-001 Crisis Team Letter ASD (24 Mar 2025)

Counter-Arguments & Rebuttals (2)

What the opponent will argue, and why they are wrong.

Court · MEDIUM Risk
They will argue

Article 14 requires a comparator. The applicant has not shown a non-disabled person in similar circumstances would have been treated differently.

Rebuttal

Cohen's own remark provides the comparator: 'had you had counsel maybe you would have won.' A represented party WOULD have won. The disability prevented effective representation (ADHD impacting self-advocacy, no legal aid). Rather than providing adjustments to level the playing field, the court punished the disability. Cam v Turkey: disability discrimination engages Article 14.

Authorities: AUTH-CASE-032
Rebuttal Confidence 7/10
Defendant · MEDIUM Risk
They will argue

The applicant chose to litigate in person. That is not the court's responsibility.

Rebuttal

No legal aid available. No pro bono counsel available for complex multi-party commercial litigation. Costs of representation prohibitive (defendants' solicitors charging GBP 350+/hour). LiP status is not a 'choice' but a consequence of resource inequality compounded by disability. EA 2010 s.20 imposes a DUTY on the court to adjust, regardless of how the person came to be unrepresented.

Authorities: AUTH-CASE-027; AUTH-STAT-003
Rebuttal Confidence 7/10

Evidence Chain (2 proof trails)

EC-009 OVERWHELMING (10/10)
12 RA requests, 0 granted (100% refusal rate)
Primary Evidence
CHE-RA-001 (RA Requests Log) + JR-DOC-004 (Schedule of 12 RA Requests) LOG CONCLUSIVE

Logged and scheduled. 12 requests across 6 courts, 7 judges. 0 granted.

Corroborating Evidence (7)
  • LRP-DEF-002 (Defence para 17.4) ADMISSION CONCLUSIVE
  • F-COHEN-REMARK ('had you had counsel maybe you would have won') JUDICIAL_ADMISSION CONCLUSIVE
  • MDE-MED-002 (Dr Woolley Report) EXPERT STRONG
  • FACT-EQUALITY-002 (ADHD diagnosis 06.11.2024) MEDICAL CONCLUSIVE
  • FACT-EQUALITY-003 (ASD diagnosis 24.03.2025) MEDICAL CONCLUSIVE
  • HMRC-COR-001 (HMRC declining RA) INSTITUTIONAL_RECORD STRONG
  • HMRC-COR-002 (Letter to HMRC RA request) CORRESPONDENCE STRONG
Overall Strength: OVERWHELMING
EC-031 STRONG (8/10)
Costs disparity: Shoosmiths GBP 28,533 for one hearing vs LiP GBP 0
Primary Evidence
LRP-CC-N260-001 (Shoosmiths N260 Statement of Costs, GBP 28,533) FINANCIAL_RECORDS CONCLUSIVE

Official costs statement. Bowden-Brown GBP 590/hr. Fairley brief GBP 11,000.

Corroborating Evidence (4)
  • F-COSTS-LIP-STANDARD (2,239 hours, GBP 79,430 at standard rate) CALCULATION STRONG
  • F-COSTS-LIP-INDEMNITY (GBP 952,640 at indemnity rate) CALCULATION MODERATE
  • F-COHEN-REMARK ('had you had counsel maybe you would have won') JUDICIAL_ADMISSION CONCLUSIVE
  • R (UNISON) v Lord Chancellor [2017] UKSC 51 LEGAL_AUTHORITY STRONG
Overall Strength: STRONG

Ground Dependencies

If This Ground Succeeds
  • AR-8
  • AR-15
  • Discriminatory treatment finding. Cohen's 'had you had counsel' statement evidences treating disability as fault. Systemic remedy for LiP treatment.
If This Ground Fails
  • G-A11
  • G-A12
  • JR-19
  • Court finds no differential treatment (contradicts Cohen's own words). EA 2010 grounds (G-A11, G-A12) and JR-19 provide domestic law equivalent.

Fallback: Article 14 adds Convention dimension to EA 2010 claims. Not strictly necessary if domestic discrimination succeeds.

Independence: Partially dependent on other grounds succeeding.

Where This Appears

Case Assignment

LRP/Vista

Linked Facts (2)

FACT-EQUALITY-001 FACT-EQUALITY-002

Linked Exhibits (2)

MDE-MED-002 MDE-MED-001

Linked Authorities (2)

European Convention on Human Rights, Article 14 Cam v Turkey (2016) 65 EHRR 32
Admin Notice Parts: V · Relief: I · All Grounds · Relief Sought · Argument Map

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