A void order is a nullity from inception. It does not need to be set aside. It does not become valid through the passage of time. There is no limitation period for challenging a void order because there is nothing to challenge. It never existed in law.
MacFoy v United Africa Co Ltd [1962] AC 152: "You cannot put something on nothing and expect it to stay there. It will collapse."
Isaacs v Robertson [1985] AC 97: A void order requires no application to set aside. It is a nullity ab initio.
Lees v Kaye [2022] EWHC 1151 (QB): "The court has no discretion. The statute says the action is void."
21 orders in these proceedings are void. 10 were made during the Mental Health Crisis Moratorium (Regulation 7(12) DSRR 2020, mandatory nullity). 6 are derivative nullities under the MacFoy principle. 2 are jurisdictional voids (Fourie v Le Roux; SI 2014/817). 2 are void for breach of natural justice, statutory duty, and EA 2010 (DM Glover; ICC Judge Greenwood). 1 is an arrest warrant void on 5 independent grounds. Zero are merely voidable. Every order is void. Not a single order had adequate reasons. No amount of time changes a void order into a valid one. The limitation argument fails at the first hurdle.
The Applicant was in a documented Mental Health Crisis Moratorium from 28 December 2024 to 16 April 2025 (110 days). During this period, all enforcement action was prohibited by statute. Regulation 7(12) DSRR 2020 states that any action taken during a moratorium "shall be null and void."
The court was on notice of the Moratorium from 29 December 2024 (notification letter sent). It proceeded to seal 5 orders during the protected period. Those orders are void by operation of statute, not by judicial discretion.
Any time that elapsed during the 110-day MHCM period cannot be counted against the Applicant. He was under statutory protection. The system that now argues "too late" is the same system that acted unlawfully during the period when the Applicant was unable to respond.
8 EX107 transcript applications were filed across three courts. Zero full hearing transcripts were provided. The only transcript received was a judgment-only transcript from HHJ Kelly, revised by the judge before release, after 2 months of bureaucratic loops.
The full hearing transcripts contain the evidence of procedural unfairness: Ross's false statements made in real time, what judges actually said versus what was recorded, whether ADHD adjustments were offered, the basis for costs orders on unsealed applications.
A party cannot be time-barred from challenging proceedings when the court has withheld the very evidence needed to formulate the challenge. The court cannot refuse transcripts and then argue that the Applicant was too slow in identifying the errors those transcripts would have revealed.
Article 6 ECHR: The right to a fair trial includes the right to the materials necessary to challenge the proceedings. Withholding transcripts and then enforcing time limits is a denial of access to justice.
The Applicant has ADHD and ASD (Equality Act 2010 s.6). HMCTS RA Reference 67862925 was issued. 12 requests for reasonable adjustments were made across 10+ judges and 6 courts. Zero were granted.
The court is under a statutory duty to make reasonable adjustments (EA 2010 s.20, PD 1A). Failure to do so renders the proceedings procedurally unfair. Per Galo v Bombardier [2016] NICA 25, wholesale failure to make reasonable adjustments may require proceedings to be set aside.
ADHD causes executive function impairment: difficulty with deadlines, processing delays, inability to prioritise, and overwhelm under procedural complexity. Every procedural deadline was a barrier that the court was obliged to adjust for and did not. The Applicant cannot be penalised for missing deadlines that were not adjusted for his disability.
The Rolls Building sent a wheelchair ramp leaflet in response to an ADHD adjustment request. That is the level of institutional understanding. The system that failed to accommodate the disability now seeks to rely on the consequences of its own failure.
A Limited Civil Restraint Order was imposed on 27 February 2025 (MHCM Day 61). No defendant applied for it. It was the court's own initiative. It prevents the Applicant from filing applications without permission from the very court that imposed it.
The LCRO was founded on TWM certifications made during the MHCM (void by operation of statute). A void LCRO cannot found an Extended Civil Restraint Order. But while it stands, it prevents the Applicant from challenging the void orders that underpin it. This is the circularity trap documented throughout these proceedings.
A party who is restrained by the court from filing applications cannot be criticised for delay in filing those applications. The time that elapsed while the LCRO was in force must be excluded from any limitation analysis.
The right of access to a court must be practical and effective, not theoretical and illusory (Airey v Ireland [1979] 2 EHRR 305).
The Applicant faced: void costs orders he could not pay, an LCRO preventing applications, transcript refusals preventing appeal preparation, CE-File deletions destroying filed documents, wrong case numbers blocking default judgment, and zero reasonable adjustments. At every turn, the system created barriers and then counted the time those barriers consumed against the Applicant.
R (UNISON) v Lord Chancellor [2017] UKSC 51: The right of access to justice is constitutional. It cannot be defeated by procedural technicalities imposed by the very system that denied that access.
Under EA 2010 s.123(3)(a), conduct extending over a period is treated as done at the end of the period. The failure to make reasonable adjustments is a continuing omission, not a one-off event. It began with the first hearing and has not ended. No adjustment has ever been made.
The 29:0 decision ratio is ongoing. The arrest warrant is outstanding. The LCRO is still in force. The transcripts are still withheld. The void costs orders are still being enforced. The discrimination is not historic. It is current. Limitation does not begin to run on a continuing act until the act ceases.
Barclays Bank v Kapur [1991] 2 AC 355: Where the discriminatory act is continuing, time runs from the last act, not the first.
The Administrative Notice (para 7(h)) argues that extending time limits is itself a reasonable adjustment under EA 2010 s.20. The duty to make reasonable adjustments is anticipatory and non-delegable. Where a provision, criterion, or practice (such as a filing deadline) puts a disabled person at a substantial disadvantage, the court must take reasonable steps to avoid that disadvantage.
ADHD causes executive function impairment, including difficulty meeting deadlines, processing complex procedural requirements, and prioritising tasks under stress. A filing deadline is a provision, criterion, or practice. It puts the Applicant at a substantial disadvantage. Extending the deadline is a reasonable step. The court has a statutory duty to take it.
EA 2010 s.20(3)-(5): The duty applies to any provision, criterion, or practice that puts a disabled person at a substantial disadvantage. Time limits are provisions.
Paulley v FirstGroup [2017] UKSC 4: The duty requires more than a policy. It requires action to remove the barrier. A deadline that a disabled person cannot meet is a barrier.
No court has made this adjustment. 0/12 reasonable adjustment requests were granted. The time limits the respondents now rely upon are the very barriers the court was obliged to adjust.
Where delay is caused by the court's own conduct, that delay cannot be held against the applicant. The Administrative Notice (para 7(i)) identifies the circularity: the court created the barriers (void orders, LCRO, CE-File deletion, transcript refusal), then counts the time those barriers consumed as a reason to refuse relief.
This circularity is itself a ground for extension. Per R (Gerber) v Wiltshire Council [2016] EWCA Civ 84, good reason for delay includes systemic failures by the public body itself. Per Denton v TH White [2014] EWCA Civ 906, the court considers the reason for the default. Where the reason is the court's own conduct, the default is not the applicant's to answer for.
Void orders do not need to be set aside (MacFoy, Isaacs v Robertson). The Applicant did file a set-aside application. It was deleted from CE-File. He then filed again. The LCRO prevented it. He then appealed. The N460 PTA refusal was pre-emptive and itself void (made during MHCM). At every step, the system blocked the very remedy it now says should have been pursued earlier.
CPR 54.5 requires JR claims to be filed "promptly and in any event not later than 3 months." But the court has discretion to extend time where there is good reason. Here: (1) the MHCM was a statutory barrier for 110 days; (2) the LCRO prevented filing; (3) no transcripts were provided to identify the grounds; (4) the Applicant has ADHD causing executive function impairment; (5) the discrimination is ongoing (EA 2010 s.123(3)(a)). Per R (Gerber) v Wiltshire Council [2016] EWCA Civ 84, good reason for delay includes systemic failures by the public body itself.
CPR 52.12(2)(a) allows extension of time for appeals. The test is whether it is just to extend. Here: the orders being appealed are void (no time limit applies). Even if they were not void, the Applicant was in MHCM (110 days of statutory protection), had zero reasonable adjustments, and was denied the transcripts needed to formulate grounds. Per Denton v TH White [2014] EWCA Civ 906, the court considers the seriousness of the default, the reason for it, and all the circumstances. The "default" here was caused by the court's own conduct.
The Applicant has filed 8 transcript applications, 12 reasonable adjustment requests, 4 default judgment requests, multiple set-aside applications (one deleted from CE-File), a formal judicial complaint, a subject access request (395+ days overdue with no response), and the current Administrative Notice, which is prepared but not yet filed. He built an entire legal technology system to manage his cases. He has not been dilatory. He has been obstructed. The 29:0 decision ratio is not evidence of delay. It is evidence of a system that rejects everything he files regardless of merit or timing.
CPR 3.9 does not apply to void orders. There is no sanction to seek relief from because the order imposing the sanction is a nullity. The unless order (DDJ Wood, 6 January 2025, MHCM Day 9) is void. The costs orders are void. The LCRO is void. CPR 3.9 applies to valid orders that have been breached. These orders were never valid.
Laches requires both unreasonable delay AND prejudice to the other party. The defendants have suffered no prejudice from any delay. Chelsea Harbour has not filed a defence in 540+ days. LRP/Vista filed 27 days late with no relief. The defendants' own delays dwarf any delay attributed to the Applicant. Per Fisher v Brooker [2009] UKHL 41, laches does not apply where the defendant's own conduct contributed to the delay.
At every angle, the time bar argument fails.
Void orders have no time limit. The MHCM was a statutory barrier. The transcripts were withheld. Zero adjustments were made. The LCRO blocked applications. Article 6 requires effective access. The discrimination is ongoing. Extending time limits is itself a reasonable adjustment. The court caused the delay.
Nine independent grounds. Any one defeats the argument. All nine apply simultaneously. The system that created every one of these barriers cannot now rely on the time those barriers consumed as a defence to their own unlawful conduct.