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/Relief Sought
In the Court of Appeal
(Civil Division)
CA-2024-001353

Relief Sought

Comprehensive summary of all orders and declarations sought across the Appeal, Judicial Review, and Consolidation proceedings
19Grounds of Voidness
7JR Targets
21Void Orders
6Cases to Consolidate
£8.2M+Total Quantum
Scope. This page sets out ALL relief sought across ALL proceedings. The relief is organised by proceeding type because the legal tests are different. The Court of Appeal corrects errors by the lower court. Judicial Review declares public body actions unlawful. The Consolidation Request brings everything before one judge.
Part 1: Appeal Relief (CA-2024-001353)

Orders the Court of Appeal is asked to make on its own motion or upon granting permission to appeal. These correct errors by the lower courts.

A. Emergency Relief (Liberty at Stake)

  1. Stay the arrest warrant (DJ Mauger, 19.11.2025) pending determination of jurisdictional challenge. The warrant is void on 5 independent grounds. Article 5 ECHR (right to liberty).
  2. Order transcripts at public expense for all hearings. 8 outstanding EX107 applications remain unanswered after 200+ days. The Applicant cannot properly present his appeal without transcripts of the hearings being challenged. R (on the application of UNISON) v Lord Chancellor [2017] UKSC 51.

B. Declarations (Void Orders)

The following orders are void ab initio and require no setting aside. The Court is asked to declare them void so that no party can enforce them.

  1. Declare void all 10 MHCM-period orders made between 28.12.2024 and 16.04.2025 under Regulation 7(12) DSRR 2020. Specifically:
    • DDJ Wood, 06.01.2025: Unless Order / Costs Order (Day 9)
    • Master Kaye, 05.02.2025: s.130(2) Leave Refusal (Day 39)
    • Master Kaye, 06.02.2025: Interim Payment Ruling (Day 40)
    • Master Kaye, 06.02.2025: Stay & Strike Out Order (Day 40)
    • Master Kaye, 27.02.2025: Costs Order (Day 61)
    • Master Kaye, 27.02.2025: LCRO (Day 61)
    • Master Kaye, 27.02.2025: N460 Permission Refusal (Day 61)
    • Master Kaye, 27.02.2025: Stay of Enforcement Order (Day 61)
    • Master Kaye, 27.02.2025: Pre-service Stay on BL-2025-000147 (Day 61)
  2. Declare void the pre-service transfer orders (Master Clark, 13.08.2024; Deputy Master Dovar, 03.09.2024). Fourie v Le Roux [2007] UKHL 1: a court cannot exercise jurisdiction over a claim that has not been served.
  3. Declare void the summary judgment (Recorder Cohen KC, 19.08.2025) as a derivative nullity. The summary judgment rests on the void transfer. MacFoy v United Africa Co [1962] AC 152: you cannot put something on nothing and expect it to stay there.
  4. Declare void the PE transfer order (Chief ICC Judge Briggs, 23.07.2025). Corporate insolvency matters are reserved to the High Court ICC in London (SI 2014/817 Sch 1). The transfer to Central London County Court was ultra vires.
  5. Vacate the LCRO (Master Kaye, 27.02.2025) as void (MHCM Day 61) and independently tainted by apparent bias. The LCRO was imposed 7 days after a formal complaint about the same judge. Porter v Magill [2002] 2 AC 357.

C. Default Judgment and Case Restoration

  1. Enter default judgment in BL-2024-001089 (Chelsea Harbour, R1). 540++ days in default. No defence filed. No application for extension of time. Mandatory under CPR 12.3(1).
  2. Restore BL-2024-001166 (former County Court ref L10CL352) to the High Court. The pre-service transfer is void. Vacate the summary judgment as a derivative nullity. Restore the case to the position it was in before the void transfer.
  3. Lift the void stay on BL-2025-000147 (personal damages). The stay was imposed before service during the MHCM. It is void and should be declared so.
  4. Enter default judgment or order R2/R3 to re-serve their defence in BL-2024-001166 (former County Court ref L10CL352). Defence filed 27 days late. No relief from sanctions sought under CPR 3.9. No application for extension of time filed. Denton v TH White [2014] EWCA Civ 906.
  5. Revert the case listing in BL-2024-001166 (former County Court ref L10CL352). The County Court unilaterally reversed the parties, listing Eastwood as Defendant despite being the Claimant. This must be corrected to reflect the true procedural posture.

D. Consolidation and Case Management

  1. Consolidate all 6 proceedings under CA-2024-001353 before one judge. All cases arise from the same root cause (the unlawful forfeiture). Separate management has produced 29 adverse decisions, 21 void orders, and jurisdictional chaos across 3 courts.
  2. Retain exclusive jurisdiction over quantum in the Court of Appeal or assign to an untainted High Court judge. All lower courts that have dealt with these cases are compromised by the bias complaint and the void orders that were never corrected. No fair assessment of quantum can take place before a judge who participated in the 29:0 pattern.
  3. Transfer PE proceedings back to High Court ICC from Central London County Court (ultra vires transfer by Chief ICC Judge Briggs).

E. Procedural Safeguards

  1. Neutral judicial allocation. No judge who has previously made orders in any of these proceedings. The 29:0 decision ratio across multiple judges creates a reasonable apprehension of systemic bias.
  2. Standing PD 1A reasonable adjustments protocol binding on all courts dealing with these cases: scheduled breaks, email service in lieu of CE-File, 14-day response buffers, written aids permitted, clear language in all court communications, single point of contact at each court centre.
  3. Costs on indemnity basis for the Applicant as a litigant in person. CPR 44.2; CPR 46.5. The conduct of the lower courts in making 21 void orders, refusing all 12 RA requests, and withholding all 8 transcripts justifies departure from the standard basis.

F. Judicial Conduct

  1. Referral to the JCIO regarding Master Kaye. Complaint filed 20.02.2025. 13+ months without investigation. 6 orders made in a single day (27.02.2025), 7 days after the complaint, including an LCRO that cited the complaint itself as justification.
  2. Referral to the JCIO regarding Recorder Cohen KC. Judge swap on day of hearing (from HHJ Kelly, who had read the papers, to Recorder Cohen KC, who had not). Summary judgment granted without the judge reading the claimant's evidence. Claimant's email access denied while opponent was permitted access. Flannery v Halifax duty breached (no reasons given).
  3. Referral to the JCIO regarding DDJ Wood, Master Clark, Deputy Master Dovar, and Chief ICC Judge Briggs in respect of orders made during the MHCM or without jurisdiction.
Part 2: Judicial Review Relief (7 Public Bodies)

Relief sought against public bodies whose decisions or failures were unlawful. These are the subject of a Part 54 JR claim (permission sought). The test is not whether the judge was wrong (that is the appeal) but whether the public body acted irrationally, illegally, or with procedural unfairness.

G. Against HMCTS (HM Courts and Tribunals Service)

  1. Mandatory order requiring HMCTS to provide all outstanding transcripts (8 EX107 applications, 200+ days unanswered).
  2. Mandatory order requiring HMCTS to respond substantively to the 16 ignored emails.
  3. Mandatory order requiring HMCTS to implement reasonable adjustments under RA Ref 67862925 and explain why they were not implemented despite formal registration.
  4. Declaration that HMCTS acted unlawfully in deleting the CE-File case without notice.
  5. Mandatory order requiring HMCTS to comply with all outstanding Subject Access Requests under the Data Protection Act 2018.

H. Against the JCIO

  1. Mandatory order requiring the JCIO to investigate the formal complaint against Master Kaye (filed 20.02.2025, 13+ months without substantive response).
  2. Declaration that the JCIO acted unlawfully in failing to investigate within a reasonable time under the Constitutional Reform Act 2005 s.108.
  3. Declaration that using a judicial conduct complaint as evidence against the complainant (Master Kaye Ruling at [41]) creates a chilling effect on the statutory complaints mechanism and is procedurally unfair.

I. Against the Insolvency Service (Official Receiver)

  1. Quashing order regarding the arrest warrant (DJ Mauger, 19.11.2025) obtained during the MHCM breathing space in breach of Regulation 7(12) DSRR 2020.
  2. Mandatory order requiring the Official Receiver to investigate the company's claims (estimated value £9.2M) under IA 1986 s.132.
  3. Mandatory order requiring the Official Receiver to provide the company's bank statements to the director.
  4. Mandatory order requiring the public examination to take place in the correct court (High Court ICC, not Central London County Court).
  5. Declaration that the Official Receiver misrepresented the contact history (claiming no further contact when 40+ contacts are documented).

J. Against the SRA (Solicitors Regulation Authority)

  1. Mandatory order requiring the SRA to investigate the 4 false statements under oath by Steven Ross of Harold Benjamin across two separate courts. Perjury Act 1911 s.1.
  2. Mandatory order requiring the SRA to investigate the 1,336-page misleading bundle filed in BL-2024-001089.
  3. Declaration that the SRA failed in its regulatory duty by not investigating clear documentary evidence of professional misconduct (SRA Code of Conduct, Principles 1 and 2).

K. Against HMRC

  1. Declaration that HMRC breached its duty to make reasonable adjustments (EA 2010 s.20) by refusing adjustments (Mrs S Huntley, 22.02.2024) and proceeding to gazette and petition despite disability disclosure.
  2. Declaration that HMRC breached the Public Sector Equality Duty (EA 2010 s.149) by failing to have due regard to the need to eliminate discrimination before initiating the winding-up petition.
  3. Mandatory order requiring HMRC to comply with outstanding Subject Access Requests.
  4. Damages for the consequential loss flowing from the discriminatory winding-up petition (the entire insolvency chain).

L. Against DWP

  1. Declaration that the 24-hour UC closure following disability rights assertion was retaliatory and unlawful (EA 2010 s.15; s.27 victimisation).
  2. Damages for the period of wrongful benefit withdrawal, subsequently proved wrong by LCWRA award.

M. Against the BSB (Bar Standards Board)

  1. Mandatory order requiring the BSB to investigate Stephanie Tozer KC (Falcon Chambers) regarding the filing of a defence 27 days late without seeking relief under CPR 3.9 and the subsequent misstatement of law in the skeleton argument.
Part 3: Systemic Relief (Access to Justice)

These orders would prevent the same failures from affecting other disabled litigants in person. The Applicant submits that the systemic nature of the failures (29:0 across multiple judges, zero adjustments across multiple courts) demonstrates institutional failings that require structural remedies.

N. Reasonable Adjustments Standards

  1. Order the Chancery Division to update its disabled accommodations guidance to explicitly address neurodivergent litigants (ADHD, ASD), including: written instructions, extended time limits, structured hearings, permission to use electronic aids, and designated support contacts.
  2. Order HMCTS to publish and implement a standard reasonable adjustments protocol for neurodivergent litigants in person, covering: email service in lieu of CE-File, 14-day response buffers, scheduled breaks during hearings, clear language requirements, and a named contact for adjustment queries.
  3. Order that all courts dealing with these proceedings must actively accommodate the Applicant's diagnosed ADHD and ASD under PD 1A and EA 2010 s.20, with adjustments recorded on the court file and monitored for compliance.

O. Litigant in Person Access

  1. Order HMCTS to ensure that all lower courts provide equal procedural treatment to litigants in person, including equal access to email communication, equal time for submissions, and equal notice of hearings. The 29:0 pattern demonstrates that the current system does not provide equality of arms.
  2. Order that transcripts be provided to litigants in person at public expense where they cannot afford them and the transcripts are necessary for appeal. ECHR Art 6; R (UNISON) v Lord Chancellor [2017] UKSC 51.

P. Subject Access Requests and Data Protection

  1. Mandatory order requiring all respondent public bodies (HMCTS, HMRC, DWP, Insolvency Service) to comply with all outstanding Subject Access Requests within 30 days. Data Protection Act 2018 s.45; UK GDPR Art 15.
  2. Order requiring HMCTS to explain why CE-File data was deleted and to restore the deleted case data.

The Applicant seeks 52 orders and declarations across 3 proceedings.

This is the only way to correct the void cascade, restore access to justice, compel the regulatory bodies to investigate, set enforceable standards for disabled litigants, and prevent the continued enforcement of orders that are legally non-existent.

Cross-References

21 Void Orders · 29:0 Decision Ratio · 7 JR Targets · 19 Grounds of Voidness · Quantum: All Claims · 0/12 Adjustments Granted · Transcript Obstruction · Subject Access Requests · Why One Judge Must Hear All

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