M. D. Eastwood
/
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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Pre-Action Protocol Letters
CPR Part 54 / Judicial Review Pre-Action Protocol
https://www.michaeldariuseastwood.com/legal/pre-action-letters
Legal/Pre-Action Letters
In the Court of Appeal
(Civil Division)
CA-2024-001353
Between
Michael Darius Eastwood
(Representing As Mastermind Promotion Ltd and Mastermind Group Ltd)
Claimant / Appellant / Applicant (Litigant in Person)
and
Chelsea Harbour Ltd, Lower Richmond Properties Ltd
and Vista (London) Ltd
Defendants / Respondents

Pre-Action Protocol Letters

Before commencing judicial review proceedings under CPR Part 54, the Claimant must comply with the Judicial Review Pre-Action Protocol. This requires sending a letter before claim to the proposed defendant, setting out the decision challenged, the grounds, and the remedy sought. The defendant must respond within 14 days.

This site is published under the open justice principle. All court proceedings referenced here are matters of public record. Read the full disclaimer.
7
Letters Drafted
1
Sent
1
Deadline Expired
0
Responses
CPR Part 54 Pre-Action Protocol. The Judicial Review Pre-Action Protocol (Annex A to Practice Direction 54A) requires a claimant to send a letter before claim to the proposed defendant before issuing proceedings. The letter must identify the decision under challenge, the date of that decision, the claimant's grounds, and the remedy sought. The defendant should respond within 14 days. Failure to follow the protocol may result in costs sanctions. The Claimant has complied with this requirement for DWP. Letters for the remaining 6 bodies are drafted and ready for service.

Public Bodies

7 public bodies have been identified as potential respondents or interested parties in judicial review proceedings. Each is detailed below with their failures, PAP status, and JR grounds.

  1. 1.HM Courts and Tribunals Service
  2. 2.Judicial Conduct Investigations Office
  3. 3.Insolvency Service / Official Receiver
  4. 4.Solicitors Regulation Authority
  5. 5.Bar Standards Board
  6. 6.Department for Work and Pensions
  7. 7.HM Revenue and Customs

Letters Before Claim

HM Courts and Tribunals Service

PRIMARY RESPONDENT (N461)
102 Petty France, London SW1H 9AJ
DRAFTED
Complaint Filed 20 February 2025 Complaint Status No response (13+ months) PAP Letter Drafted. Not yet sent. JR Grounds JR-1, JR-2, JR-7, JR-8, JR-11, JR-12, JR-13, JR-16, JR-19, JR-20

Documented Failures (9)

  • HMCTS-F1Default judgment N227 suppressed 540+ days (filed 04.09.2024)
  • HMCTS-F28 EX107 transcript applications ignored 200+ days
  • HMCTS-F3SAR non-compliance 395+ days (filed 20.02.2025, UK GDPR Art 15)
  • HMCTS-F4CE-File deleted set-aside application (a CE-File administrator, 16.08.2024)
  • HMCTS-F516 substantive emails ignored
  • HMCTS-F60/12 reasonable adjustment requests granted (RA Ref 67862925)
  • HMCTS-F7Judge swap Dight to Cohen unexplained (19.08.2025)
  • HMCTS-F8'Mr Darius' on EX107 forms (a County Court clerk, 18.09.2025)
  • HMCTS-F917 orders made without CPR 23.1 applications
JR-1 JR-2 JR-7 JR-8 JR-11 JR-12 JR-13 JR-16 JR-19 JR-20

Judicial Conduct Investigations Office

PRIMARY RESPONDENT (N461)
81-83 Queensway, London W2 4QN
DRAFTED
Complaint Filed 20 February 2025 Complaint Status No response (13+ months) PAP Letter Drafted. Not yet sent. JR Grounds JR-21

Documented Failures (3)

  • JCIO-F113+ months ignoring formal complaint about Master Kaye
  • JCIO-F2LCRO imposed 7 days after complaint (possible retaliation per Porter v Magill)
  • JCIO-F3No investigation of ICC Judge Greenwood victimisation
JR-21

Insolvency Service / Official Receiver

PRIMARY RESPONDENT (N461)
4 Abbey Orchard Street, London SW1P 2HT
DRAFTED
Complaint Filed OR letter sent (OR_Response_FINAL) PAP Letter Drafted. Not yet sent. JR Grounds JR-3, JR-4, JR-9, JR-15

Documented Failures (5)

  • IS-F1Arrest warrant under wrong statutory provisions (ss.290/364 bankruptcy for company)
  • IS-F2PE proceedings in wrong court (CLCC not ICC). s.117(2A) IA 1986.
  • IS-F3Abandoned GBP 9.2M claims without investigation
  • IS-F4Demands documents while withholding them (impossibilium)
  • IS-F5No reasonable adjustment assessment (EA 2010 s.20)
JR-3 JR-4 JR-9 JR-15

Solicitors Regulation Authority

INTERESTED PARTY
The Cube, 199 Wharfside Street, Birmingham B1 1RN
DRAFTED
Complaint Filed Pre-action letter drafted PAP Letter Drafted. Not yet sent. JR Grounds JR-10

Documented Failures (4)

  • SRA-F1No investigation of Steven Ross 4 false statements
  • SRA-F2No investigation of 1,336-page misleading bundle (06.02.2025)
  • SRA-F3No investigation of enforcement during MHCM (Harold Benjamin, Dec 2024-Apr 2025)
  • SRA-F4No investigation of failure to notify court of moratorium
JR-10

Bar Standards Board

INTERESTED PARTY
289-293 High Holborn, London WC1V 7HZ
CONDITIONAL
Complaint Status Conditional on SAR results PAP Letter Drafted. Sending conditional on HMCTS SAR disclosure. JR Grounds JR-14

Documented Failures (1)

  • BSB-F1No investigation of counsel conduct during MHCM (Core Duties 1, 3, 5; Rules rC3, rC4)
JR-14

Department for Work and Pensions

RESPONDENT
Caxton House, Tothill Street, London SW1H 9DA
DEADLINE EXPIRED
Complaint Filed 18 February 2026 PAP Letter Sent 18 February 2026 14-Day Deadline 5 March 2026 (EXPIRED) Response No substantive response. JR can now be filed. SAR Status SAR submitted 18.02.2026. Deflected to GOV.UK form. 30-day deadline expired 18.03.2026. JR Grounds JR-5, JR-18 Quantum LCWRA arrears: 9,300. Sanction deductions: 900. Total: 10,200.

Documented Failures (10)

  • DWP-F1UC sanctions cascading from void winding-up (CR-2024-000527)
  • DWP-F2Disability-related inability to comply with void requirements (EA 2010 s.15)
  • DWP-F3Two-year failure to action WCA requests (Feb 2024 to Feb 2026). LCWRA arrears: 9,300.
  • DWP-F4Case manager Conor lost MR for 5 months (Sept 2025 to Feb 2026). Gaslighting documented.
  • DWP-F5Claim Review initiated within 24 hours of MR asserting EA 2010 disability rights. Prima facie retaliation.
  • DWP-F6Claim closed 04.12.2025 while claimant was actively submitting evidence. DWP later admitted error.
  • DWP-F7SAR deflected to GOV.UK form. 30-day deadline expired with no compliance.
  • DWP-F8Pre-action protocol letter. 14-day deadline expired with no substantive response.
  • DWP-F9UC accessibility system excludes neurodivergent conditions. Forces 'No adjustments required'.
  • DWP-F10LCWRA award (16.02.2026) proves ALL prior sanctions were unlawful.
JR-5 JR-18

HM Revenue and Customs

INTERESTED PARTY
HMRC Solicitor's Office, Bush House, Strand, London WC2B 4RD
DRAFTED
Complaint Status Pre-action letter drafted, offers consent to rescission PAP Letter Drafted. Not yet sent. JR Grounds JR-6

Documented Failures (3)

  • HMRC-F1Winding-up petition without RA assessment (Mrs Huntley refused 22.02.2024)
  • HMRC-F2Winding-up petition gazetted same day as ADHD disclosure (21.02.2024)
  • HMRC-F3No alternative enforcement considered (Time to Pay, R&D credits). Liability reducible from 243,153 to under 43,000.
JR-6

Timeline

Key dates in the pre-action protocol process.

20 February 2025
Formal complaints filed
Complaints submitted to HMCTS and JCIO. SAR also filed to HMCTS on same date.
18 February 2026
DWP pre-action protocol letter sent
Letter before claim sent to DWP via UC journal. SAR also submitted on same date.
5 March 2026
DWP 14-day deadline expired
No substantive response from DWP. JR proceedings can now be commenced.
18 March 2026
DWP SAR 30-day deadline expired
DWP deflected SAR to GOV.UK form. No data provided. UK GDPR Art 12(3) breach.
Pending
Remaining 6 letters to be sent
HMCTS, JCIO, Insolvency Service, SRA, HMRC drafted. BSB conditional on SAR results.

Legal Framework

The pre-action protocol for judicial review is mandatory. It serves the overriding objective by encouraging early resolution and ensuring the court has proper notice of the claim.

Judicial Review Pre-Action Protocol (Annex A, PD 54A)

The protocol requires the claimant to send a letter before claim to the proposed defendant identifying the decision under challenge, the date of the decision, a summary of the facts, the legal grounds for the claim, the remedy sought, and the claimant's address. The defendant should normally respond within 14 days. Failure to follow the protocol may result in costs consequences under CPR 44.2.

CPR Part 54 (Judicial Review)

Part 54.5 requires that a claim for judicial review must be filed promptly and in any event within 3 months after the grounds to make the claim first arose. The pre-action protocol must normally be followed before issuing the claim form. Where the defendant fails to respond to the letter before claim, the court may take this into account when considering permission and costs.

CoA Guide 2025, Chapter 6 (Retained JR Procedure)

Where judicial review is sought in the Court of Appeal under s.31A of the Senior Courts Act 1981 (as retained), the pre-action protocol still applies. The Court of Appeal Guide 2025, Chapter 6, confirms the procedural requirements for applications that include a JR component. The 7 public bodies identified on this page are all subject to JR either as primary respondents or interested parties within the retained jurisdiction.

EA 2010 s.20 (Reasonable Adjustments)

Each public body has a duty under the Equality Act 2010 s.20 to make reasonable adjustments where a provision, criterion, or practice puts a disabled person at a substantial disadvantage. The pre-action letters include specific reasonable adjustment requests. The SAR process itself is a reasonable adjustment under EA 2010 s.20, as it enables a disabled litigant in person to access records necessary to prosecute his claim effectively.

Related Pages

DWP Judicial Review Institutional Failures JR Targets (7 Bodies) Subject Access Requests SAR Tracker RA Tracker (0/12) ECHR Violations OR Response

Statement of Truth

I believe that the facts stated on this website are true. I understand that proceedings for contempt of court may be brought against anyone who makes, or causes to be made, a false statement in a document verified by a statement of truth without an honest belief in its truth.

Michael Darius Eastwood

Litigant in Person

ADHD + ASD (Equality Act 2010 s.6) | HMCTS RA Ref: 67862925

London, United Kingdom

© 2026 Michael Darius Eastwood. Published under the open justice principle.

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