Kiloran Properties Limited v Amanda Clutterbuck & Anor [2026] EWCC 49

IN THE COUNTY COURT AT WANDSWORTH
Date 18/08/2026
On appeal from the order of District Judge Avent
76-78 Upper Richmond Road Putney SW15 2SU
HHJ MARQUAND
[2026] EWCC 49Case No K00WT410Case No Between:KILORAN PROPERTIES LIMITED (ACTING BY MR MARK BAILEY AND MR RICHARD PARKINSON AS JOINT LPA RECEIVERS)Claimant/AMANDA CLUTTERBUCK (1)Defendant/PERSONS UNKNOWN (2)AppellantCase Nos: K00CL035, M00WT296KILORAN PROPERTIES LIMITED (ACTING BY MR MARK BAILEY AND MR RICHARD PARKINSON AS JOINT LPA RECEIVERS)Claimant/IAN PATON (1)Defendant/PERSONS UNKNOWN (2)Appellant
Rabby Fozlay (instructed by Spencer West) for Appellant Miss ClutterbuckMr Ian Paton in person for in personThomas Rothwell (instructed by TLT LLP) for RespondentHearing Hearing dates: 5 May & 22 July 2026
Approved JudgmentThis judgment was handed down in open court..............................HHJ MARQUAND

HHJ Marquand:

[1]The Respondent/Claimant (“Kiloran”) seeks possession of 2 properties. First, Flat 1, 44-45 Hans Place, London SW1X 0JZ (“Hans Place”) and 80 Pavilion Rd (First Floor Flat) London SW1X 0ES (“Pavilion Road”). Hans Place is occupied by Miss Clutterbuck and Pavilion Road by Mr Paton (together the “Appellants”). The claims are brought through LPA receivers appointed by the Bank of Scotland under charges over Hans Place dated 5 June 2007 and Pavilion Road dated 22 April 2008. The receivers were appointed on 24 February 2022.[2]There are 2 proceedings against each property, both on the basis of trespass (the “First Proceedings” and the “Licence Proceedings”). The Licence Proceedings allege, following service of notices to quit, that the licences relied upon by both Miss Clutterbuck and Mr Paton as a defence to the First Proceedings have been terminated.[3]In each pair of claims, the Appellants, Miss Clutterbuck and Mr Paton, appeal the decision of District Judge Avent (the “Judge”) made on 15 August 2025 making an order for possession. This is a “rolled up” hearing, in other words permission to appeal will be decided and if successful the appeal will follow immediately thereafter. Due to issues that arose during the hearing, it was adjourned for further submissions and Mr Paton requested a further oral hearing, which I allowed.[4]At the beginning of the hearing, the Appellants made various applications to amend the grounds of appeal and to adduce fresh evidence. I refused all of those applications for the reasons that I gave at the time.[5]Mr Fozlay represented Miss Clutterbuck, Mr Paton represented himself and Mr Rothwell represented Kiloran. There is a considerable degree of overlap between the position of Miss Clutterbuck and Mr Paton as will become apparent. I am grateful to all parties for their written and oral submissions.

Background

[6]Background Miss Clutterbuck is the beneficial owner of Kiloran. This is a company incorporated in Jersey. Kiloran is the registered leasehold owner of Hans Place and Pavilion Road. One of the restrictions on the title for Hans Place is in favour of a person known as “SA”. There is in place an order from the High Court anonymising this individual, whose relevance will become apparent.[7]In 2010 Miss Clutterbuck and Mr Paton commenced proceedings against SA making a number of allegations against her including fraudulent misrepresentation, deceit and breach of trust arising out of various property dealings. During those proceedings Kiloran gave an undertaking on behalf of Miss Clutterbuck in relation to SA’s costs. Judgment was delivered on 20 February 2014 in favour of SA and an award of costs made in her favour. An interim payment on account of costs was ordered in the sum of £1 million on 3 April 2014 and that was paid by way of £260,000 on 3 September 2014 and £740,000 on 9 November 2016. The total amount of costs that eventually became due was £1,616,414 and there were other costs orders in SA’s favour.[8]On 4 July 2019 Miss Clutterbuck and Mr Paton were adjudged bankrupt. This was as a result of proceedings brought by a third party.[9]In July 2021 SA had a court-appointed deputy and brought proceedings against Kiloran and Bank of Scotland seeking to obtain the unpaid costs from the equity in Hans Place and information about the equity in Pavilion Road. Those proceedings were compromised by way of a confidential settlement agreement on 5 October 2023. Neither Miss Clutterbuck nor Mr Paton have had access to that confidential settlement agreement. In fact, Kiloran and Bank of Scotland have refused to provide a copy.[10]SA had maintained that she was born in Saudi Arabia. However, in relation to litigation over her immigration status, the First-Tier Tribunal found that she was a Yemeni citizen and stated: “[SA] deliberately and dishonestly sought to conceal her Yemeni citizenship…” (quoted at paragraph 22 of SA v Secretary of State for the Home Department [2025] EWCA Civ 357). Her appeal on a technical point was rejected.[11]On 26 April 2015 Miss Clutterbuck’s father died and she became his sole executrix of the Clutterbuck Trust. The Clutterbuck Trust and Mr Ben Paton (Mr Ian Paton’s brother) exchanged a contract for sale of Hans Place with Kiloran. The contract records the price as £1.4 million, with a deposit of £35,000 and remaining balance of £1,365,000. It is at around this time that Miss Clutterbuck went into occupation of Hans Place. On 10 April 2016, Mr Ben Paton loaned £850,000 to Miss Clutterbuck and Mr Ian Paton. The purpose of the loan was to enable payment to be made to SA for the interim payment on account of costs. The sum of £740,000 was paid by Kiloran to SA’s solicitors. As a result of the terms of the loan, the contract for sale of Hans Place was amended to record that a payment of £775,000 had been made leaving a balance of £625,000. It was also agreed that Kiloran would remove the restriction on title in SA’s favour before completion. It appears that removal of that restriction did not form part of the settlement agreement of 5 October 2023.

Procedural history First Proceedings Hans Place

[12]Procedural history First Proceedings Hans Place Before the issue of proceedings, Miss Clutterbuck did not set out any legal basis for her remaining in possession. Proceedings were issued on 6 April 2023 and Miss Clutterbuck filed a defence form and witness statement alleging that she had an “implied tenancy”. The initial hearing was adjourned as it was argued that there was no right to create any tenancy without the Bank’s agreement and the court allowed Miss Clutterbuck to raise a defence that she was a licensee. Miss Clutterbuck filed an amended defence claiming that since the exchange of contracts she occupied Hans Place as Kiloran’s licensee. A trial date was adjourned twice due to lack of time/judicial availability.

Procedural history of First Proceedings Pavilion Road

[13]Procedural history of First Proceedings Pavilion Road Mr Paton did not respond to any pre-action correspondence. Kiloran issued proceedings in the County Court at Central London. Kiloran failed to attend 2 hearings and the claim was struck out, but subsequently restored on Kiloran’s application. Mr Paton filed a defence, which was in similar terms to that of Miss Clutterbuck, namely that he was a licensee. Following a hearing on this case, given the similarity to the First Proceedings for Hans Place, it was transferred to the County Court at Wandsworth so that they could be heard together. Due to administrative issues, this did not happen initially.

Procedural history of the Licence Proceedings

[14]Procedural history of the Licence Proceedings Kiloran decided, without prejudice to its position in the First Proceedings, to serve notices to quit on the occupiers of Hans Place and Pavilion Road on the basis that Miss Clutterbuck and Mr Paton stated that their right of occupation was as licensees. Proceedings were issued and an application was listed on 21 March 2025 but a consent order was approved by the court and dated 17 April 2025. The key parts of the order are as follows: i) all 4 claims would be managed together; ii) Miss Clutterbuck and Mr Paton were to serve defences to the License Proceedings by 4 PM on 5 May 2025; iii) Kiloran to file any reply by 4 PM on 2 June 2025; and iv) at paragraph 8:
“The Claims [i.e. all 4 of them] shall be listed for a further hearing, for final disposal or additional directions, on the first open date after 23 June 2025, with a time estimate of 3 hours, at which the court shall consider: a) whether, on the basis of the parties’ statement of case, a possession order should be made against the defendant (or any of them); and b) if not, what further directions are necessary to progress the Claims to trial.”
The hearing referred to at paragraph 8 was listed for 15 August 2025.[15]Miss Clutterbuck asked for an extension of time for service of her defence as she had been taken to hospital and had a forthcoming operation. On 29 April 2025 Kiloran agreed the 1st extension to 2 June 2025. On 29 May 2025 Miss Clutterbuck’s solicitors requested a further extension due to her ill-health and this was agreed to by Kiloran with the defence now falling due on 11 July 2025. On 10 July 2025 Miss Clutterbuck requested a third extension and an adjournment of the hearing on 15 August 2025. This request was also made on Mr Paton’s behalf. The reasoning was again Miss Clutterbuck’s ill-health. I will return to the detail of Miss Clutterbuck’s ill-health below. Kiloran refused this request although expressed sympathy for Miss Clutterbuck’s condition.[16]On 1 August 2025 Miss Clutterbuck made an application for relief from sanction, a retrospective extension of time to file her defence and “directions to serve any Part 20 claims or additional claims relevant to the claim and the proceedings linked to this claim”. It was accompanied by a witness statement of Miss Clutterbuck of 68 paragraphs over 10 pages, the key points of which were: i) the background to Miss Clutterbuck’s occupation and the contract for sale of Hans Place were set out. ii) Miss Clutterbuck maintained she had a licence to occupy (paragraph 16). iii) she had an interest in Hans Place as trustee of the Clutterbuck Trust. iv) the solicitors (Strafford law) handling the purchase of Hans Place had closed down and documents concerning the transaction could not be recovered. v) Completion of the sale had not been possible because the SA restriction had not been removed by Kiloran and Strafford law. If it had completed then there would have been more than sufficient equity to discharge the Bank of Scotland mortgage at that time. vi) Bank of Scotland had not provided the redemption figure or a copy of the confidential agreement with SA. vii) Miss Clutterbuck had atrial fibrillation and heart failure. She was admitted as an emergency to hospital “over 9 times”. The last admission was on 4 July 2025 following a collapse in “hypertension crisis”. In February 2025 she underwent a coronary angiogram and echocardiogram. She received emergency cardioversion whilst waiting an emergency cardio ablation. The normal waiting time for which in the NHS was 40 weeks, but an appointment was made on 16 May 2025. There were hypertension crisis complications during the 4-hour operation. She was kept in hospital. After discharge she was readmitted with a hypertension crisis and acute ablation chest pain diagnosed as pericarditis. The ablation procedure took 3 months for recovery without post-surgical complications, she stated. In March 2025, she collapsed at home requiring an emergency admission with prolonged QTC requiring implantation of a cardiac loop monitor. As a result of her health condition, she was medically unfit to deal with legal matters or provide full and proper instructions. She was heavily medicated and unable to focus on correspondence or review documentation. On 10 July 2025 she was too unwell to give proper and full instructions to file her defence and any counterclaim, given the last admission on 4 July 2025. Copies of correspondence are exhibited to the statement. These are as follows I have omitted some of the administrative correspondence (they were not exhibited in chronological order and I have re-ordered them): Type of document and date Date of any admission and discharge Nature of correspondence 1 Discharge summary dated 29 December 2024 27 December 2024 and 29 December 2024 Admission for atrial fibrillation and treatment. 2 2 January 2025 from outpatients n/a Appointment on 4 February 2025 3 6 January 2025 letter from A&E to GP n/a Details 4 previous attendances at A&E and one on 6 January 2025 with palpitations and atrial fibrillations and “to return tomorrow”. 4 6 January 2025 from outpatients n/a Appointment 22 January 2025 in person cardiology 5 22 January 2025 n/a Advice on blood pressure management 6 27 January 2025 outpatient n/a Cardiology telephone appointment 11 June 2025 7 30 January 2025 letter from GP n/a Unwell over past month and “paramount” avoids undue stress including legal matters “for the next few months” 8 4 February 2025 letter from consultant cardiologist n/a Sent home in early hours of 4 February from A&E and advises urgent admission on that day 9 7 February 2025 4 February 2025 and discharge on same day “Known case of AF was initially attended A&E on 3rd Feb with chest pain, palpitation and syncope. She underwent CT aortogram which revealed normal result. After giving fluid and Mg, patient was discharged on 4th Feb morning. then (sic) was reviewed at cardiology clinic and cardiology consultant send (sic) the patient back to A&E for IP investigation. Then she had invasive coronary angiogram which showed no obstruction of arteries and so she was discharged with urgent referral to Electrophysiology studies.” 10 18 February 2025 outpatients n/a Appointment cardiology 13 August 2025 11 19 February 2025 n/a DC cardioversion appointment 22 February 2025 12 25 February 2025 outpatients n/a Appointment cardiology 12 March 2025 13 26 February 2025 from GP n/a Unwell over past 2 months and “paramount” avoids undue stress including legal matters “for the next few months” 14 10 March 2025 from consultant cardiologist n/a Refers to multiple emergency department visits with episodes of atrial fibrillation and supports ablation. 15 Undated department of nuclear medicine n/a Appointment 18 March 2025 perfusion scan 16 26 March 2025 n/a Notification of admission to cardiac day ward and attached leaflet about ablation. Including: “You may be able to go home the same day but most people will need to stay overnight in hospital for observation” 17 Discharge summary 2 April 2025 30 March 2025 and 2 April 2025 Symptoms of dizziness, chest discomfort and possible palpitations 18 4 April 2025 pacemaker department n/a Device check appointment 21 May 2025 19 Undated from CT scanning n/a Appointment for 1 May 2025 20 3 May 2025 outpatient booking n/a Cardiology appointment 18 March 2026 21 Discharge summary 17 May 2025 16 May 2025 and 17 May 2025 Catheter ablation for cardiac arrhythmia. Admitted overnight for blood pressure monitoring 22 19 May 2025 MRI appointment n/a Notification of in person appointment on 26 June 2025 23 19 May 2025 from appointments n/a Notification of in person cardiology appointment on 9 July 2025 24 Discharge summary 19 May 2025 18 May 2025 and no date of discharge recorded Post ablation peri-myocarditis 25 9 June 2025 from Community cardiology and respiratory team n/a Notification of telephone appointment on 2 July 2025 26 4 July 2025 letter from GP n/a This refers to recent cardiac procedure and complications and further review. It states: “She is currently not medically well to attend any court hearings” viii) Miss Clutterbuck accepted the failure to serve the defence on time was a significant breach. The reason given for default were her health issues and inability to provide timely and detailed instructions. All the circumstances of the case are stated as that since 11 July 2025 she had acted as promptly as she could, given her ill-health. She stated she had a meritorious defence and counterclaims. She relied upon the counterclaims involving Kiloran and Bank of Scotland including the confidential settlement with SA, despite them knowing of her “false identity”. ix) Miss Clutterbuck went on to detail the additional claims and counterclaims as follows: a) a claim for an equitable interest and/or proprietary estoppel based on substantial expenditure incurred in reliance on the contract of sale and revised contract, since Miss Clutterbuck’s occupation of Hans Place. b) a claim for specific performance and/or breach of contract and/or restitution against Kiloran for not completing the contract for sale. c) a claim against Bank of Scotland for unlawful interference and refusal to provide a redemption figure and its collusion with SA and Kiloran when entering into a confidential settlement agreement “with a known identity fraudster”. x) Miss Clutterbuck set out further detail about the claims against Kiloran and Bank of Scotland and also details the claim against SA to set aside the judgment she obtained in 2014 (see above).[17]Mr Paton made a similar application dated 9 August 2025. His witness statement dealt with the following: i) Mr Paton relied on Miss Clutterbuck’s statement and covered much the same ground as she did. He relied upon the prospective claims that Miss Clutterbuck identified. ii) He stated he had contributed to significant payments towards external works on Pavilion Road. He set out more detail on SA and stated that the Bank of Scotland were on notice of the identity fraud. iii) Mr Paton stated that his ability to plead the defence has been hindered by Miss Clutterbuck’s serious ill-health, concealment of the confidential settlement agreement, ongoing litigation in particular referring to the Court of Appeal decision “confirming SA’s fraud” and the need for disclosure from Kiloran and the Bank of Scotland. iv) Mr Paton dealt with the 3-stage test in Denton and under the heading “seriousness and significance” acknowledged missing the deadline to file a defence. However, he stated that no trial date had been lost and that the delay was tied to Miss Clutterbuck’s serious ill-health and the evolving findings of fraud by the Court of Appeal and the lack of disclosure of material evidence. The overriding need was for the court to decide possession on complete factual basis. As to the reasons for default, he stated that facts were concealed by virtue of the October 2023 confidential settlement agreement, the serious continuing ill-health of Miss Clutterbuck, the need to incorporate the findings of fraud relating to SA in the Court of Appeal and the need for further disclosure. In all the circumstances Mr Paton stated that his defence was strong, the receivers were appointed in bad faith and there was an abuse of power by Bank of Scotland. If the receiver’s appointment was determined to be void he stated then the possession claim cannot stand. Refusing relief would cause extreme prejudice by depriving him of his home without a determination of the true issues. Any prejudice to the Claimant/Respondent from delay was limited and proportionate to the gravity of the evolving situation.

Hearing before the Judge

[18]Unfortunately, there is no transcript of the hearing before the Judge as the equipment was not working on 15 August 2025. However, Mr Fozlay and Mr Rothwell were both counsel below and have prepared a note of the judgment that is agreed between them. However, it is not agreed by Mr Paton.[19]In the judgment, the Judge set out the background to the matter and what had happened procedurally. He also set out the background concerning SA and then dealt with the relief from sanction applications and the relevant law. He set out CPR 3.9 and summarised the 3 stages in Denton. The Judge dealt with each defendant separately, because their positions were slightly different. The Judge recorded that Mr Fozlay conceded that the failure to file a defence was a serious and significant omission and the Judge applied the same conclusion to Mr Paton’s application. The Judge made the following findings: i) This was a straightforward termination of a licence claim. After 7 months no defence had been filed. A consent order extended time for the defence and there were 2 further extensions of time and the defendant’s own deadline had not been met, which was a serious and significant event. The overriding objective included enforcing compliance with rules, practice directions and orders. The parties were required to assist the court in furthering the overriding objective. Miss Clutterbuck and Mr Paton failed to do this and that the first stage of the Denton test was clearly met. ii) He did not accept Miss Clutterbuck’s evidence that she had been admitted to hospital 9 times as an emergency, but stated “the best I can do is count 3 times.” The Judge accepted that she had undergone a serious procedure, but was not prepared to accept without medical evidence that this would have “laid her low” for 3 months. There were no admissions to hospital after the procedure. Given her 68 paragraph witness statement she was:
“clearly quite capable to give instructions” and it would be no different to prepare a defence. iii) Miss Clutterbuck was somewhat disingenuous when she gave instructions that she was a licensee, if she knew full well that she was a beneficial owner or the beneficiary of an estoppel. The Judge concluded she ought to have raised those matters and he did not accept that there was a good reason for failing to file a defence. He accepted the medical evidence up to the timing of the ablation procedure, but not that she was unable to give instructions for her defence. He agreed with Mr Rothwell that this was either because there was no defence or it was a delaying tactic. iv) In considering all the circumstances, the Judge included compliance with court orders and moving litigation through the courts in a reasonable and proportionate manner. He stated: “I am satisfied that this could all have been dealt with a long time ago and [Miss Clutterbuck] should not be entitled to benefit from her own omission.” v) In dealing with Mr Paton’s position, he did not accept that Mr Paton could wait until Miss Clutterbuck filed her defence, he said there was no justification for him to wait. He was not entitled to any greater indulgence as he was acting as a litigant in person. He had met Miss Clutterbuck several times but did not ask what her defence might be. vi) The Judge concluded that both applications should have been issued much earlier and commented that the court may take such delay into account although it is not a determinative factor. vii) The Judge concluded: “I find there is no good reason for [Mr Paton’s] failure to file a defence nor do I find that, in all the circumstances, there should be relief granted.” viii) The additional claims that Miss Clutterbuck wished to bring were dealt with. First, a claim for unlawful interference by the Bank of Scotland had no real prospect of success. The Bank and SA were not parties to the litigation. The confidential settlement agreement between those 2 persons had nothing to do with Miss Clutterbuck or Mr Paton. ix) Any claim for an equitable interest or proprietary estoppel would have vested in the trustee in bankruptcy and there was no right to bring a claim in respect of it. The Judge was satisfied that when the bankruptcy was discharged they did not revest and the rights had been lost. In any event, bringing a claim for specific performance as a result of non-completion appeared completely academic because Miss Clutterbuck owned Kiloran. There was no list of expenditures incurred by Miss Clutterbuck. x) In the Judge’s opinion, the applications had the hallmarks of “smoke and mirrors defence” and were a further attempt to delay matters. The Judge refused relief from sanction for both Miss Clutterbuck and Mr Paton. xi) The Judge then considered CPR 55.8. The Judge said that the licences had been terminated and that that was “the end of the matter”
. He stated:
“I should add that I consider all potential claims by [Miss Clutterbuck] and [Mr Paton] to be very likely to have no real prospect of success whatsoever and the reason is simply this. The bank’s legal mortgage and legal charge clearly has priority.”
If there are arguments against SA and Kiloran those will attach to the proceeds of sale. The Judge gave possession of Hans Place and Pavilion Road forthwith. I have dealt with the specific details of the judgment under the relevant ground of appeal.

Grounds of appeal

[20]Miss Clutterbuck has raised 5 grounds of appeal the first two of which relate to the Judge’s evaluation of the medical evidence and her ability to provide instructions. The third relates to an error in the analysis of the 3rd stage of Denton. The fourth ground challenges the analysis there was no defence to the claim. The fifth alleges the Judge was wrong to make an order for possession in circumstances where Miss Clutterbuck had not been able to provide instructions based on an interpretation of the orders dated 17 April and 30 April 2025. Mr Paton’s grounds of appeal are 11 in number and there is an overlap with Miss Clutterbuck’s grounds. Rather than seek to summarise them I will deal with them under the discussion/reasons section below.[21]There was some conflation between Miss Clutterbuck’s grounds 3 and 4 that had not been addressed in written submissions but arose in the course of submissions, in particular the consequences of HRH Prince Abdulaziz Bin Mishal Bin Abdulaziz Al Saud v Apex Global Management Ltd [2014] UKSC 64 at [29], per Lord Neuberger, which I raised with the parties. In addition, grounds 4 and 5 raised the issue of whether and how the Judge was required to deal with CPR 55.8.[22]I formulated 2 questions and ordered the parties to provide written submissions namely: i) When applying the Denton test to an application for an out-of-time extension to file and serve a defence, should the Court take into account the merits of a potential defence when considering all the circumstances of the case under the third stage in Denton (the “First Question”)? ii) Having decided not to extend time for a Defence, was the Court required at the hearing on 15 August 2025 to consider the test set out at CPR r.55.8(2)/the summary judgment test (the “Second Question”)?

The Law

[23]CPR 52 governs appeals and the relevant extracts (omitting irrelevant wording) are as follows: i) CPR 52.6 – “(1) …permission to appeal may be given only where—(a) the court considers that the appeal would have a real prospect of success; or(b) there is some other compelling reason for the appeal to be heard.” ii) CPR 52.21 – “(3) The appeal court will allow an appeal where the decision of the lower court was— (a) wrong; or (b) unjust because of a serious procedural or other irregularity in the proceedings in the lower court.”[24]A “real prospect of success” is the same as the test for summary judgment (see below). In CPR 52.21 “wrong” may mean an error of law, fact or an error in the exercise of discretion (Note 52.21.5 to the White Book). The principles applicable to an appellate court’s approach to a first-instance court’s discretionary evaluation were summarised in Azam v University Hospital Birmingham NHS Foundation Trust [2020] EWHC 3384 (QB) at [50], as approved by the Court of Appeal in ABP Technology Ltd v Voyetra Turtle Beach Inc [2022] EWCA Civ 594; [2022] E.T.M.R 33 at [21]. They are that the appeal court will only interfere with the discretionary evaluation where one, or more, of the following errors is identified: a misdirection of law; some procedural unfairness or irregularity; that the Judge took account of irrelevant matters; that the Judge failed to take account of relevant matters; or, the Judge’s decision was “plainly wrong”, i.e. it exceeded the “generous ambit within which reasonable disagreement is possible.”[25]It is agreed that the test to be applied is the one in CPR 3.9 when an application for an extension of time is made after expiry of the deadline. This rule is headed “Relief from sanction” and it states:
“(1) On an application for relief from any sanction imposed for a failure to comply with any rule, practice direction or court order, the court will consider all the circumstances of the case, so as to enable it to deal justly with the application, including the need— (a) for litigation to be conducted efficiently and at proportionate cost; and (b) to enforce compliance with rules, practice directions and orders. (2) An application for relief must be supported by evidence.”
[26]This rule was considered in the well-known cases of Mitchell v News Group Newspapers Ltd [2013] EWCA Civ 1537; [2014] 1 W.L.R. 795 and then Denton v TH White Ltd [2014] EWCA Civ 906. The three stages in Denton are: first, the significance of the breach, secondly, the reason for the breach and thirdly, all the circumstances of the case so as to enable the court to deal justly with the application. Those circumstances include the first two stages and the requirements of rule 3.9(1)(a) and (b).[27]Mr Fozlay and Mr Rothwell were agreed that HRH Prince Abdulaziz Bin Mishal Bin Abdulaziz Al Saud v Apex Global Management Ltd [2014] UKSC 64 at [29], per Lord Neuberger and Christine Bangs v FM Conway Limited [2024] EWCA Civ 1461 were authority for the general rule that the merits of the underlying claim are irrelevant for a case management decision on whether to grant relief from sanction. The exception to that general rule is where a party wishes to contend its case is so strong that it would be able to obtain summary judgment in its favour. This should only be taken into account where this can be readily demonstrated without detailed investigation. A party wishing to rely upon such an argument must give clear notice of such an intention to enable the other party to decide what evidence on the merits it wishes to deploy. The other party is not expected to deploy the full extent of the evidence that it would at trial. What is required is sufficient evidence to demonstrate that summary judgment is likely to be inappropriate.[28]The relevant parts of CPR 55.8 state: “(1) At the hearing fixed in accordance with rule 55.5(1) or at any adjournment of that hearing, the court may— (2) Where the claim is genuinely disputed on grounds which appear to be substantial, case management directions given under paragraph (1)(b) will include the allocation of the claim to a track or directions to enable it to be allocated.”(a) decide the claim; or(b) give case management directions.[29]In Global 100 Ltd v Laleva [2021] EWCA Civ 1835; [2022] H.L.R. 20 the test of whether the claim is genuinely disputed on grounds which appear to be substantial was found to be the same as the test for summary judgment in CPR 24.3. Namely, has the defendant shown a real prospect of success in defending the claim. The principles applicable to determining such applications are set out in AC Ward & Sons Ltd v Catlin (Five) Ltd [2009] EWCA Civ 1098 at [24]. In particular, the claim must have a realistic prospect of success. Realistic means it carries some degree of conviction and is more than merely arguable.

Discussion and reasons

[30]Discussion and reasons Miss Clutterbuck – ground 1 This ground is that the Judge erred in fact by finding that Miss Clutterbuck had only been admitted to hospital as an emergency 3 times, instead of at least 6 times. Mr Fozlay submitted that this was a material error of fact that vitiated the decision and the Judge failed to understand properly, analyse or consider the evidence. Mr Fozlay submitted that Miss Clutterbuck had faced serious health issues and complications and her evidence should be accepted. Mr Rothwell’s arguments were that the respondent accepted Miss Clutterbuck had been admitted 3 times, but the other episodes relied on did not amount to separate emergency admissions. The dates are also before the consent order and it was difficult to see how they were relevant. The Judge accepted Miss Clutterbuck had undergone an ablation but he was right to accept that being kept overnight was not an emergency, given the note given to patients.[31]In her witness statement, Miss Clutterbuck stated that she was admitted as an emergency to the hospital’s “Resuscitation Department” on 27 December 2024 and subsequently was admitted “as an emergency over 9 times.” It is agreed between the parties that the episodes on 27 December 2024, 3 February 2025 and 30 March 2025 amounted to emergency admissions that were accepted by the Judge who stated: The Judge was taken through the medical evidence by Mr Fozlay and referred to Miss Clutterbuck being admitted on 3 February and discharged on 4 February. The Judge stated there was no medical intervention at all in April until the ablation on 16 May. The Judge accepted this was a serious procedure but did not accept that it would “lay her low” for the next 3 months. He stated that following the ablation there had been no admissions to hospital. “…the best I can do is count 3 times. She has certainly been to hospital but that is for various appointments and checkups and there is no suggestion that she has suffered from heart failure or been at death’s door during these checkups.”[32]Mr Fozlay submitted that there was a separate emergency admission on 4February 2025. As can be seen from the table of the medical evidence at paragraph 14 row 8 and 9 what happened was that Miss Clutterbuck attended accident and emergency on 3 February, had a CT aortogram and treatment but was then discharged on the morning of 4 February. She was reviewed at an outpatient clinic on the same day and she was sent back to A&E for further investigations. This then resulted in her further discharge on 4 February. On the one hand, this might be said to be a separate emergency admission but I do not believe the Judge should be criticised for concluding that it was 1 episode of emergency treatment. From the evidence, nothing additional happened to Miss Clutterbuck to require the readmission on 4 February. The doctor in the outpatient appointment on 4 February stated:
“I was very surprised and disappointed that she had been sent home in the early hours of this morning” and that “she should be admitted to hospital immediately”
. In other words, this was 1 episode where she should not have been discharged in the first place.[33]Mr Fozlay submitted that there was a separate emergency admission on 16 May 2025 and 18 May 2025. Miss Clutterbuck was admitted for the ablation procedure on 16 May 2025 (not an emergency in itself) and discharged on 17 May 2025. In her witness statement she referred to a “hypertension crisis complications” and being kept in hospital. She also refers to a readmission “as an emergency” with a “hypertension crisis and acute ablation chest pain diagnosed as pericarditis”. The Judge accepted the ablation was a serious procedure and that she had a slight relapse immediately after the operation and then an outpatient appointment on 21 May 2025 for a loop recorder. Paragraph 16 rows 16, 21 and 24 cover these episodes. The discharge summary identifies that Miss Clutterbuck suffered from high blood pressure during the procedure that responded to treatment and there were no other complications. The leaflet provided to patients (row 16) identifies that most patients will need to stay overnight. The Judge cannot be criticised for his assessment that this was not an emergency admission and there is no indication in the evidence that the decision to keep the patient in hospital was an “emergency”. The Judge does not specifically refer to the 18 May 2025. The discharge summary indicates that this was all dealt with on the same day when Miss Clutterbuck presented with chest pain, underwent investigations and was sent home on the same day with a diagnosis of post-ablation peri-myocarditis and treatment with aspirin and colchicine tablets. It is a moot point as to whether this amounts to an emergency admission, but there is nothing in the discharge summary to support an argument that the Judge’s conclusion that this was a “slight relapse” was wrong.[34]Mr Fozlay also referred to the correspondence at paragraph 16 row 3 as showing 4 admissions which together with the 3 the Judge found made 7. He also relied upon Miss Clutterbuck’s witness statement at paragraph 28 where she stated that she was admitted on the 4 July 2025. However, there was no documentation of that admission before the Judge. Mr Fozlay said that amounted to 8 emergency appointments and there were 6 at least.[35]The Judge made an assessment of the factual evidence that was before him. Miss Clutterbuck in her statement said she had been admitted over 9 times. Attendances at an emergency department do not necessarily mean that an admission has taken place. It cannot be said that the Judge failed to take into account any relevant evidence or took into account irrelevant evidence. This was an evaluation that the Judge was entitled to reach and there is no real prospect of success in arguing otherwise. In any event there is more force in ground 2 in the sense that the number of admissions is not the key but rather the effect of the medical condition on Miss Clutterbuck’s ability to give instructions. I dismiss this ground of appeal as having no real prospect of success.

Miss Clutterbuck – ground 2

[36]Miss Clutterbuck – ground 2 This ground is that the Judge erred in fact and/or law by finding that there was no good reason to extend time and/or to grant relief for Miss Clutterbuck’s breach. It is submitted the Judge failed to consider properly and/or ascribe sufficient weight to the medical evidence before the court, its effect on Miss Clutterbuck and/or the difference between reviewing a witness statement and providing fresh instructions for a defence.[37]Mr Fozlay’s submissions were that the Judge had under-categorised the seriousness of Miss Clutterbuck’s health condition, referring to it as “relatively serious” and a “slight relapse” after the ablation procedure (see above). He relied upon the evidence of other admissions and the fact that the Judge had failed to consider the medical evidence as a whole. Those amounted to good reasons as they were out of Miss Clutterbuck’s control. She was too unwell to finalise the defence and counterclaim and there was no consideration of this in the judgment and there was no reason for a finding of lack of credibility. The defence covered periods of over 10 to 20 years.[38]As the Judge stated, Mr Fozlay took the Judge through the medical evidence. I have already concluded that the Judge was entitled to find that there were 3 emergency admissions. The Judge stated that Miss Clutterbuck had been in hospital but correctly, from the evidence before him, concluded that there was no evidence of heart failure or that she had been “at death’s door”. It is clear that he had considered all of the evidence and reached the conclusion that there was no medical intervention at all in April, which is not challenged. The Judge accepted that the ablation was a serious procedure but was not prepared to accept that it would “lay her low” for 3 months as there was no evidence of that. There was no evidence of an admission to hospital since the ablation. Miss Clutterbuck stated she had been admitted on 4 July, but there was no medical record of such an admission. The Judge stated he accepted the medical evidence up to the ablation but not subsequently. The Judge was giving greater weight to the evidence where it was supported by contemporaneous documentation, as he was entitled to do. Even if Miss Clutterbuck’s statement that she was admitted on 4 July 2025 was ignored completely by the Judge, it would make no material difference to the outcome in the absence of a contemporaneous medical record. The Judge’s comments go against Mr Fozlay’s submission that the Judge did not take the medical evidence as a whole into account. It is clear that the Judge did take it into account. The Judge’s focus is on the post-ablation timeframe i.e. from the middle of May to the deadline within which the defence should have been served. Given that the Judge had found, as I have found he was entitled to do, that Miss Clutterbuck had been admitted on 3 occasions and not the “over 9” that she claimed. He may have had in mind the number of items of from the medical records included in the exhibit to her witness statement that are no more than administrative documents rather than going to the substantive issue (see the table paragraph 16 above). In addition, she refers to “crisis” but no crisis is apparent from the medical records. The Judge cannot be said to have been wrong to find Miss Clutterbuck not credible. By implication, he found she was exaggerating her ill-health in order to delay submitting a defence. He found that she was capable of giving instructions because of the length and detail of her witness statement that meant a defence could have been prepared. He referred to her as being disingenuous as having given instructions in the First Proceedings that she was a licensee to now in the Licence Proceedings claiming that she had a beneficial interest and/or the benefits of proprietary estoppel. This is a logical conclusion; she must have known the factual basis upon which she occupied the property all along. The argument that the Judge was wrong to conclude that if the instructions could be given for the witness statement they could also be given for the defence is misconceived. It is said that the witness statement was prepared by solicitors from telephone/email correspondence. The witness statement is very detailed and covers the matters I have described above. Furthermore, Miss Clutterbuck stated that it has come from her own information except where stated otherwise. She does not say that it was prepared by her solicitors on the basis of telephone/email correspondence. She must have read it and confirmed its accuracy to sign the statement of truth and therefore considered the detail of it. The Judge cannot be said to be wrong to have concluded that a defence could have been prepared. There is nothing the Judge failed to take into account that he should have done and nothing that he should not have considered. There is no gap in logic. The Judge cannot be said to be wrong in this decision. I refuse permission to appeal on this ground.

Ground 3 and 4– Miss Clutterbuck and the First Question

[39]Ground 3 and 4– Miss Clutterbuck and the First Question These issues need to be dealt with together. Ground 3 concerns “all the circumstances of the case” in the 3rd stage of Denton but in Mr Fozlay’s written grounds and submissions the Judge’s assessment of the merits of the defence were not referred to but set out separately in ground 4. Before me, neither party had referred to HRH Prince Abdulaziz Bin Mishal Bin Abdulaziz Al Saud v Apex Global Management Ltd or Christine Bangs v FM Conway Limited and it does not appear that the Judge below was referred to those cases either. In fact, Mr Rothwell in his skeleton argument before the Judge below invited consideration of the merits as part of all the circumstances of the case, making the argument that there was no real prospect of success. However, it became clear in the course of argument before me that the point needed to be addressed, hence the First Question. As I have stated above, the parties were agreed on the law but Mr Fozlay said that the exception applied, but Mr Rothwell said it did not but in any event the Judge had dealt with the merits and concluded there was no real prospect of a defence.[40]As I have stated above, in the note of the judgment the Judge dealt first with Miss Clutterbuck’s application for relief from sanction, and without considering the merits reaches a conclusion that she should not be entitled to benefit from her own omission. He then deals with Mr Paton’s application and finds in all the circumstances that relief should not be granted. The Judge then goes on to consider the merits of the “additional claims” (i.e. defences) for both Miss Clutterbuck and Mr Paton that are advanced in Miss Clutterbuck’s witness statement. He rejected each of them concluding that the Appellants were seeking to delay matters and had no real prospect of success. The Judge concludes this section of the judgment stating:
“On that basis and including [Mr Paton] as well, the applications for relief are refused.”
I find that the Judge did not deal with this as 2 stage process but rather a continuum and the Judge must have had in mind his conclusion that there was no real prospect of a successful defence as he went through his analysis of all the circumstances of the case. This is not surprising given that that is what Mr Rothwell had invited him to do. Mr Fozlay, as I have stated above, maintains that the Judge was wrong to have concluded that there was no merit in those defences, as per ground 4.

Ground 3 - Miss Clutterbuck

[41]Ground 3 - Miss Clutterbuck Ground three claims that the Judge erred in fact and/or law in the assessment of what was just in all the circumstances. It is submitted that the Judge failed to properly consider and/or ascribe sufficient weight to: i) Miss Clutterbuck’s previous conduct; ii) the proportionality of the sanction or any less punitive alternatives; iii) the relevant factual background and sums already paid over; iv) the recent Court of Appeal judgment and interconnected proceedings; v) the principle that compliance is not an end in itself; and vi) and/or the overriding objective.[42]Mr Fozlay’s submissions were that this was Miss Clutterbuck’s first application for an extension of time, there was no prior failure to comply with court orders and it was only three months since the original deadline of 5 May 2025 and one month from the extended deadline of 11 July 2025. The Judge adopted the most draconian approach without considering other less draconian powers. The Judge did not consider that £775,000 had already been paid under the part completed contract for sale and that the Judge should have exercised caution given the amount of money involved. The Judge did not consider the Court of Appeal judgment and interconnected proceedings directly. Based on the underlying facts the Judge should have held it was not a straightforward case of termination of a licence. The Judge incorrectly treated compliance with the rules as an end in itself. The overriding objective meant the Judge should have given Miss Clutterbuck a final opportunity to serve a defence.[43]The Judge extensively set out the background, as I have indicated above. The litigation as a whole had been started on 6 April 2023 and the Judge had recorded that by consent Miss Clutterbuck had agreed to file a defence by 5 May 2025. The Judge also formed the opinion that Miss Clutterbuck had been disingenuous, see paragraph 19(iii) above. The Judge concluded that the defence could have been dealt with a long time ago (see paragraph 19(iv) above). The Judge clearly had in mind the circumstances and background and viewed the application in that context, including the delay in making the application, although he said that was not a determinative factor. Looking at the judgment as a whole he clearly considered that the agreed extension of time was to the 11 July 2025 and that this was a first application. This is an extempore judgment and the Judge must be afforded some latitude in the wording of the judgment (especially bearing in mind it is not a judgment approved by the Judge), but it is abundantly clear that he had well in mind the circumstances in which this application came to be made and the full history of the case.[44]As to the criticism concerning less punitive sanctions available to the Judge it was submitted by Mr Rothwell that alternatives were put to the Judge by Mr Fozlay. Mr Fozlay did not recall being asked directly in open court about any alternatives being put to the Judge and this issue was not properly ventilated. In the written reply it noted only a mediation was sought after the filing/service of a defence. Mr Fozlay did not accept any other alternatives apart from a mediation were sought. In any event, it can be seen from reading the whole judgment that the Judge was of the view that this was a matter where the defendants had no defence (and see below on for the conclusion on ground 4) and it was a delaying tactic. He had considered Miss Clutterbuck as being able to give instructions despite her medical condition and specifically stated that disproportionate time should not be given when it is not due. The Judge clearly had the overriding objective and the proportionality of the sanction in mind. For the same reasons, the Judge cannot be said to have been treating compliance with the rules as an end in itself. The Judge had evaluated all the circumstances to enable the case to be dealt with justly and concluded this was a case without a defence and therefore proceeded to refuse the extension of time, as he was entitled to do. There would be no purpose in a less draconian sanction as it would not have furthered the overriding objective to have further delayed a matter where there was no real prospect of a successful defence.[45]The reliance upon the Court of Appeal judgment in SA also does not withstand close analysis. The judgment upheld the decision of the First-Tier Tribunal on a technical point; there was no appeal against the finding of dishonesty before the First-Tier Tribunal. The Appellants’ references to the Court of Appeal finding of dishonesty are misplaced and seem to be an attempt to raise the significance of the finding to the status of one made by that court. Whilst it is important background, and obviously important to the Appellants, the Judge clearly had it in mind as he recorded it in the judgment, but the Appellants do not put forward any real argument as to how the Judge dealt with it incorrectly, but simply state it was not a factually simple case. It is not clear how the finding of SA’s dishonesty in representing herself as from Saudi Arabia as opposed to where she really came from affects these proceedings, which are based on trespass. Similarly, the payment to Kiloran of £740,000 and then the onward payment to SA and its precise relationship to these proceedings is not explained by the Appellants, but simply said to make it more complex. It is not enough to say the Judge should have exercised caution, if there is any relevance to it, the argument should have been made to the Judge and to me, which it has not been (see also below Mr Paton’s argument about fraud).[46]The evaluation by the Judge of all the circumstances of the case to enable it to be dealt with justly does not identify any error of law, any matter that should have been taken into account that was not taken into account or any matter which should have been left out of account. There is no procedural unfairness and it cannot be said to be a decision that no reasonable Judge could have reached or one that is plainly wrong. I refuse permission to appeal on this ground.

Ground four – Miss Clutterbuck

[47]Ground four – Miss Clutterbuck Ground 4 submits that the Judge erred in law and of fact by finding that the claim was not genuinely disputed on grounds which appear to be substantial or that Miss Clutterbuck had no defence. The Judge failed to properly consider and/or ascribe sufficient weight to the facts that: i) all of the elements giving rise to an estoppel and/or equitable interest had already been pleaded; ii) a substantial sum of money had already been paid over under a part completed sale of contract; iii) there was no evidence before the court as to the terms of any license or the circumstances in which it had been granted; iv) any equity in favour of the Clutterbuck Trust would be unaffected by Miss Clutterbuck’s bankruptcy; and v) Miss Clutterbuck had both legal and/or equitable defences/counterclaims;[48]Mr Fozlay submissions were that paragraph 4 of Miss Clutterbuck’s defence in the First Proceedings was that she was the “beneficial owner of Kiloran” and that at paragraph 11 she set out the elements of an estoppel. Namely that Kiloran agreed that Miss Clutterbuck should remain in Hans Place as a licensee. This was said to be the promise element. Since occupying the property, she had made significant further payments in connection with the maintenance and upkeep of the property. This is said to be the detriment element. Mr Fozlay submitted that the substantial payment under the contract of sale should have alerted the Judge to “the possibility” of creation/existence of rights. He relied upon Brake v Swift [2020] EWHC 1810 (Ch) that the vendor becomes the constructive trustee for the purchaser from exchange of contracts until completion. He submitted Kiloran held Hans Place on constructive trust. He submitted that Kiloran had not shown the Judge any licence and it had not admitted that a licence existed or any of its terms. The consent order for directions on the trial of the First Proceedings stated that a day would be needed to determine its existence, terms and the circumstances in which it was granted and therefore the Judge could not be satisfied that any license had been validly terminated. The Judge was wrong to hold that any claim for estoppel and/or beneficial interest was lost when he stated that under bankruptcy legislation all property vested in the bankrupt vests in the trustee, but they do not revest when the bankruptcy is discharged.[49]The evidence I have been shown does indicate that Miss Clutterbuck is the beneficial owner of Kiloran. However, to submit that the defence to the First Proceedings in Hans Place pleads all the elements giving rise to an equitable interest and estoppel and therefore the Judge was wrong in the conclusion that he reached is not one that I accept. Mr Fozlay argued that the beneficial interest in Kiloran led to the conclusion of a beneficial interest in Hans Place. He criticised the comment in the judgment:
“It is now said today that [Miss Clutterbuck] is the 100% beneficial owner of the shares in Kiloran and it seems the argument is that this, in turn, made her in some way the beneficial owner of Hans Place. Quite how that is possible given that Kiloran is a separate legal entity is beyond me.”
[50]I tested Mr Fozlay on the proposition and he correctly conceded that this did not follow as a matter of law. However, Mr Fozlay continued to try and argue it, submitting that this, together with the witness evidence before the Court which included confirmation that Kiloran was Miss Clutterbuck’s holding company, gave rise to a real prospect of successfully arguing an equitable interest. Of course, a person may be a beneficial owner of a company and have a beneficial interest in a property when the legal title is held by that company. However, that does not follow automatically as a matter of law. At paragraph 12 of the defence, Miss Clutterbuck pleads that as the beneficial owner of Kiloran and an interested party as one of the buyers under the contract (which personally she is not, but she is as a trustee of the Clutterbuck Trust) she had attempted to pay back the loan to the Bank of Scotland. This does not support a conclusion of a beneficial interest in Hans Place. At paragraph 14 she refers to occupying under an agreement with Kiloran and the buyers. At paragraph 15 she refers to herself as “beneficial owner” but that needs to be seen in the context of paragraph 12 i.e. the beneficial owner of Kiloran.[51]Whether there is a beneficial interest in Hans Place will depend on whether Kiloran had expressly granted such an interest, on a resulting or constructive trust or on proprietary estoppel. There is no pleading of any constructive trust. There is no specific pleading that a licence was a “promise” of the type now contended for. There is a statement that she has paid maintenance and upkeep, but there is no pleading of the expense being incurred in reliance on the “promise”. There is no pleading of “unconscionability” although Mr Fozlay submits such a failing is not fatal to such a claim. There is no counterclaim for a declaration of trust. The pleading is clearly that Miss Clutterbuck was a licensee i.e. held a personal interest and that is what the Judge concluded. He cannot be criticised for that analysis. The defence in the First Proceedings states unambiguously that she was a “licensee” at paragraphs 4 and paragraph 11 and the other paragraphs quoted above support that construction: there was an agreement she could occupy the premises.[52]The Judge refers to the defence as “substantive” and “relatively lengthy” but his conclusion was that they go no further than stating that the Appellants are licensees. The Judge has not made an error in his evaluation in the way Mr Fozlay contends. The Judge has not left anything out of account and there is no gap in logic in such an evaluation (it is not a discretion, but an evaluation of the evidence). It would be inconsistent to claim a personal right as a licensee and at the same time a beneficial interest. If there is no beneficial interest then the submissions about bankruptcy become irrelevant. In any event, when bankrupt, Miss Clutterbuck’s role as trustee would not have vested in her trustee in bankruptcy, but if declared, any beneficial interest would have vested in her trustee in bankruptcy. On the assumption that Hans Place was her principal home, any beneficial interest would have revested in her after 3 years under section 283A of the Insolvency Act 1986 assuming none of the exemptions in subsection 3 applied. There is no evidence or pleading of whether such an interest was disclosed.[53]Any beneficial interest that Kiloran holds as a constructive trustee under the contract for sale would be for the prospective purchasers, in other words, the Clutterbuck Trust and Mr Ben Paton and not for Miss Clutterbuck. Any beneficial interest that the Clutterbuck Trust and Mr Ben Paton hold would be a matter of them to enforce as would any claim for specific performance under the contract of sale. I do not follow the Judge’s logic in respect of his comments about a beneficial interest in Hans Place not revesting in Miss Clutterbuck but, as I said above the point goes nowhere as the Judge was not wrong to conclude that there was no real prospect of success in arguing that there was an equitable interest and/or proprietary estoppel. Mr Fozlay argued before me (as does Mr Paton) that the Judge had conflated the parties in particular the role of the Bank of Scotland and the Law of Property Act receivers. The Judge referred to receivers being “effectively placed in the shoes of Kiloran” but then refers to the Bank’s legal mortgage and legal charge having priority and that the Bank is entitled to pursue its remedies. There is no merit in this argument, it is clear from the judgment that the Judge appreciated the difference. In any event, the Bank is pursuing its remedies by virtue of the appointment of the Law of Property Act receivers and to say that the Judge had misunderstood the position and was wrong in reaching the conclusions that he did has no merit.[54]As to the submission on the terms of the license, it was asserted by Miss Clutterbuck that there was a licence. In her defence to the Licence Proceedings a point was taken in the defence that the claim had not been validly or effectively served. However, no pleading was made concerning the terms of the licence. Kiloran issued the Licence Proceedings on the basis that if there was a licence then it had been terminated. What was in issue to be decided at any trial of the First Proceedings was: was there a licence at all? This was what the time estimate covered. There is nothing in Miss Clutterbuck’s witness statement about the terms of any licence, and these would be matters that she should have asserted if they were in issue. It is not surprising as the case being brought in the Licence Proceedings by her was that there was a beneficial interest in the property. Nevertheless, no positive alternative case was put forward by Miss Clutterbuck. The Judge specifically stated that no argument had been made to challenge the validity of the notices to quit or service of them. This was a matter considered by the Judge and appropriately taken into account. The Judge is not required to speculate about what a party may have as a defence that has not been articulated by them in circumstances such as this. His decision cannot be challenged on this point.

Conclusion on grounds 3 and 4

[55]Conclusion on grounds 3 and 4 It follows therefore, that in considering all the circumstances of the case, including the defences raised by Miss Clutterbuck and Mr Paton that there is no real prospect of arguing that the Judge was wrong in his assessment of the 3rd stage in Denton, including his assessment of the merits of the potential defences. I do not need to decide whether he needed as a matter of law to go on to consider the merits of the defence (i.e. the First Question) as he did so as he had been invited to do by Mr Rothwell. I therefore refuse permission to appeal on grounds 3 and 4.

Ground 5 – Miss Clutterbuck and the Second Question

[56]Ground 5 – Miss Clutterbuck and the Second Question It was submitted by Mr Fozlay that the Judge had made an error in law by making a possession order where Miss Clutterbuck had not been able to provide her legal representatives with instructions or file any substantive evidence. Mr Fozlay argued that the orders dated 17 April 2025 and 30 April 2025 (see paragraph 14(iv) above) required the Judge to decide:
“(1) whether on the basis of the parties’ statements of case, a possession order should be made against the defendant (or any of them); and (2) if not, what further directions are necessary to progress the claims to trial.”
[57]It was submitted that in the absence of a statement of case, proper instructions from Miss Clutterbuck, a defence and/or any relevant witnesses the Judge should not have ordered possession but should have given a final opportunity to file a defence in light of previous orders.[58]In the subsequent written submissions, it was agreed between Mr Fozlay and Mr Rothwell that the hearing on 15 August 2025 was an adjourned hearing and therefore CPR 55.8 and the test in CPR 55.8(2) applied (this is the answer to the Second Question). Mr Fozlay argued that the claims were genuinely disputed on substantial grounds and repeated the arguments that he made under ground 4 and that additionally, the Judge should have considered the defences that had been filed in the First Proceedings and submitted he did not do so. In oral argument, Mr Fozlay stated that in the absence of a statement of case from the Appellants the Judge should have given directions and that would have been a more proportionate response, such as an unless order.[59]Mr Fozlay did not pursue in his subsequent written submissions the argument that on 15 August 2025 the Judge was bound by the previous orders in circumstances where the defence that should have been served was not. He was right not to pursue this with any particular vigour as the argument has no merit. An order was made anticipating that a defence would be served, but it was not. The Judge dealing with the matter subsequently had to take the circumstances as he found them and the previous case management order was not binding on the Judge to that extent.[60]Mr Fozlay argued that even in the absence of a formal defence, if the matter is genuinely disputed on grounds which appear to be substantial then case directions should usually be given; rather than summary disposal – as this is a court of justice; not procedure. Mr Paton sought to make similar arguments. To the extent that the argument is that having refused relief from sanction that the Judge was nevertheless, by virtue of the test in CPR 55.8(2), to consider the merits of the defences (or potential defences) in the Licence Proceedings as a matter of law is also misconceived. Counsel did not find any authorities on this point.[61]In the normal course of events, following service of the particulars of claim, under CPR 15.4 a defence must follow after 14 days. The court will fix a hearing under CPR 55.5(1) when it issues the claim form (which must be accompanied by the particulars of claim). Under CPR 55.7(3) where a defendant has not filed a defence within the time specified in CPR 15.4 they may still take part in any hearing. CPR 55.8 concerns the hearing fixed under CPR 55.5(1) or at any adjournment of that hearing and provides that the court may decide the claim or give case management directions.[62]In these cases (i.e. the ones subject to this appeal), following service of the particulars of claim in the Licence Proceedings, the application listed under CPR 55.5(1) was for 21 March 2025 and adjourned to the 15 August 2025. By consent in the order dated 17 April 2025 the defences were to be served by 5 May 2025, which was subsequently extended by agreement and then resulted in the application for an out of time extension that is the subject matter of this appeal.[63]In the normal course of events, if a defendant has not served a defence at the hearing fixed under CPR 55.5(1), then the judge would hear their submissions on any defence they may seek to rely upon. CPR 55.7(3) permits a defendant to take part and therefore to make any submissions they may have on a possible defence. The judge would decide whether that submission amounted to a genuine dispute of the claim on grounds which appeared to be substantial, in which case further directions would be given, usually for a formal defence. If the judge did not find the test in CPR55.8(2) met then they may decide the claim i.e. by making an order for possession, assuming the claimant had satisfied the necessary requirements.[64]In these cases, with regard to the Licence Proceedings, the procedure had taken a different turn of events by virtue of the consent order dated 17 April 2025. These were directions given under CPR 55.8(1)(b). The Judge concluded at the adjourned CPR55.8(1) hearing that relief from sanction should not be given for the failure to serve the defences to the Licence Proceedings within the agreed extended time limit. Therefore, whilst the Appellants had a right to take part in the proceedings (CPR 55.7(3)) they were precluded from advancing a defence to the Licence Proceedings, having been refused permission to do so. If a defendant was permitted by CPR 55.8(2) to advance a defence having been debarred from relying on one that would create a very strange set of circumstances where a court order mandating service of a defence would be rendered of no effect and it would make an application for an extension of time for service of a defence in such circumstances otiose. That would not be consistent with the overriding objective. Mr Paton made a similar argument relying on CPR 55.7(3) which expressly gives the right to take part in “any hearing”, but it does not follow that if an order has been made refusing the defendant permission to rely upon a defence that they are nevertheless be able to advance the same defence that they have been refused permission to rely upon.[65]At the first hearing where there is no procedural bar to relying on submissions and/or evidence of a defence, in the absence of that formal document, the situation is different. It provides the tenant with protection where they have a defence with a real prospect of success and the landlord with a route to a summary process where the tenant does not have such a prospect (as CPR 12 is not applicable). In Part 8 Proceedings a defendant who fails to file an acknowledgement of service may attend a hearing but not take part, unless the court orders otherwise. In contrast, in claims to which CPR 55.7(3) applies it allows a defendant to take part in the Possession Proceedings even where they have not acknowledged the proceedings (there is no requirement for an acknowledgement of service) or filed a defence. The rule allows participation even where a defendant has not up until that point declared themselves to the court and such a defendant may make whatever representations they see fit, but the rule does not oust the effect of any previous orders or of other procedural requirements.[66]Mr Fozlay’s further submissions were that, in any event, the Judge should have considered the defences that had been served to the First Proceedings. The Judge deals with this briefly stating that in relation to the licence argument, the licences have now been terminated and “that is the end of the matter”. As I have referred to above, elsewhere in the judgment, the Judge refers to the defences as “quite substantive” but states:
“but go no further than saying that [the Appellants] are licensees.”
In the First Proceedings, the claim was made that the Appellants were trespassers and that was met by the defence that they were not and the positive case advanced that they were “licensees”. The dispute in the First Proceedings was about whether there was a licence. However, as I have already stated, the Kiloran elected to terminate any purported licences by serving the notices to quit and the Judge noted that no argument had been made to challenge the validity of the notices or service of them. There was therefore no defence to the Licence Proceedings. It follows as a matter of logic that as in the First Proceedings the defences against the claim for trespass were that the Appellants were licensees that those licences had been terminated. There was no need for the Judge to set this out any more extensively than he had done and it is clear he did take the defences in the First Proceedings into account. There was nothing else to consider.

Mr Paton’s Grounds of Appeal

[67]Mr Paton’s Grounds of Appeal Mr Paton relied on a document entitled “Final Grounds of Appeal” which identifies 11 grounds. At the hearing on 5 May when the time available came to an end and I permitted written submissions, I was concerned that Mr Paton may not have had an opportunity to present his arguments to me orally. I therefore made provision that he could do so if he wished and he made such an application which I allowed that resulted in the hearing on 22 July. Mr Paton also submitted a number of documents before that subsequent hearing and I checked at the hearing that I had received copies of all of them namely: i) submissions on his authorities dated 17 May 2026; ii) written replies dated 25 May 2026; iii) reply dated 1 June 2026; iv) Mr Paton’s note on factual discrepancy in the agreed note of judgment; v) supplementary notes on the cases of Song and Ward; and vi) oral submissions dated 22 July 2026. Mr Paton also provided an authorities bundle dated 17 May 2026 and a supplementary authorities bundle on 22 July 2026. Mr Paton addressed me orally on 22 July 2026 by taking me through his document called “oral submissions”.[68]I can deal with some of the grounds fairly shortly as they raise the same arguments that I have already dealt with for Miss Clutterbuck. Ground 1 is a failure to consider the equitable interests of Mr Paton, Miss Clutterbuck, Mr Ben Paton and the Clutterbuck Trust. As stated above, there is no real prospect of success in relation to an argument that Miss Clutterbuck or Mr Paton have an equitable interest in Hans Place or Pavilion Road. Mr Paton’s position is even weaker than Miss Clutterbuck’s. His defence to the First Proceedings was that he was a licensee having the agreement of Kiloran and Miss Clutterbuck as the beneficial owner of Kiloran (although he refers only to Kiloran in another part of the Defence). It mirrors the defence served by Miss Clutterbuck. Any trust that may arise in relation to Mr Ben Paton and the Clutterbuck Trust are not relevant as they are not a party to these proceedings. Ground 2 is that Kiloran holds Hans Place on a constructive trust. Again, I have dealt with this and rejected the argument and in any event it does not assist Mr Paton as he is in occupation of Pavilion Road. Ground 3 is that the Judge mischaracterised the receiver’s role. It is argued that the Judge misapplied agency principles. I have already rejected any argument that the Judge failed to identify correctly the roles played by the receivers and the Bank of Scotland.[69]Ground 4 alleges that the Judge failed to address the invalidity of the undertaking on 25 March 2011. Mr Paton argues that on 28 March 2025 the Court of Appeal confirmed SA’s Saudi identity was “void ab initio” and that the receivers cannot lawfully rely on a defective undertaking to justify possession. Ground 5 alleges that the Judge refused to scrutinise the settlement of 3 October 2023 between SA, Kiloran and the Bank of Scotland. Mr Paton argues that it is downstream of SA’s fraud and that it deliberately excluded the equitable interests of Mr Ben Paton, the Clutterbuck Trust, Miss Clutterbuck and him. Ground 8 alleges the Judge failed to apply the principle that fraud “vitiates jurisdiction” and therefore argues that the receivers cannot rely on SA’s defective undertakings, restrictions or costs orders to justify possession. Ground 9 alleges that the Judge ignored binding Court of Appeal rulings of 28 March and 1 August 2025 which, Mr Paton argues, expunge SA’s Saudi persona and invalidate all matters based upon that finding. He argues that it fundamentally alters the legal foundation for possession. In essence, Mr Paton’s argument is that SA was fraudulent at the very beginning of the chain of events in the claim that he and Miss Clutterbuck brought against her. Everything “downstream” must fall as a result of her fraud. Mr Paton relies upon a number of authorities, including a judgment handed down the day before the hearing on 22 July 2026 in particular, Song & Anor v Smith & Ors [2026] EWCA Civ 719, Ward & Ors V Donnellan & Ors [2026] EWCA Civ 729 and Salinas Pliego v Astor Asset Management 3 Ltd [2026] EWCA Civ 940.[70]Song is a case where there was a dispute between business owners and misappropriation of assets was alleged. Mr Paton relies on it to show that those issues were of the kind requiring substantive evaluation rather than summary disposal by reference to a formal label or procedural outcome. Ward is an appeal against a costs order where there were findings of dishonesty made by the first instance judge. Mr Paton relied on Ward only to show that those issues were of the kind requiring substantive evaluation rather than summary disposal by reference to a formal label or procedural outcome. Salinas Pliego concerns an appeal over “privilege hunting” and what the court’s response should be. Mr Paton relied on this to show 4 propositions. First, that a strong case on merits that might succeed on summary judgment was nevertheless refused, as there was a compelling reason for the case to go to trial. Secondly, the court's response to procedural misconduct must protect its process, be proportionate, and consider effective alternatives. Thirdly, directly connected abuse may deprive a party of a procedural or discretionary advantage without determining the underlying claim finally. Fourthly, the new authority reinforces the request for a focused oral hearing. I did not find any of these authorities helpful, as for the reasons I have already given I have upheld the Judge’s conclusions. Summary disposal was a decision the judge was entitled to reach and was proportionate and in accordance with the overriding objective.[71]Mr Paton and Miss Clutterbuck may be able to set aside the judgment that SA has in her favour. However, that does not automatically follow because the First-Tier Tribunal has found that she was not a Saudi Arabian national as she had claimed. The judgment and the orders that were made remain binding until they are set aside and that will not happen automatically. The Court of Appeal judgment does not find that the fraud impacts on this litigation, although I appreciate that Miss Clutterbuck and Mr Paton believe that it does. Mr Paton claims that there has been a fraud and Mr Paton alleges that there was collusion by the Bank of Scotland and Kiloran in reaching a settlement with SA that they will not now disclose. There is no evidence to support such an allegation (I make no comment on whether there was a relevant fraud) but that does not alter the position before the Judge. The Bank of Scotland has secured charges against Hans Place and Pavilion Road, in those circumstances it was entitled to appoint receivers to obtain possession of the properties. If there has been injustice to the parties as a result of a fraud and costs orders are to be set aside in the future, then that will be resolved in separate proceedings by a taking account of the payments that have been made. This was a point made by the Judge when at the conclusion of the judgment he stated that if there are arguments against SA or Kiloran those will attach the proceeds of sale.[72]Ground 7 alleges the Judge erred in refusing the relief from sanction application and in the application of the test in Denton. I have already dealt with this under grounds 3 and 4 raised by Miss Clutterbuck and for the same reasons I find there is no real prospect of success for Mr Paton. Ground 6 alleges a misapplication of the effect of the Insolvency Act 1986. I have already dealt with this above and for the same reasons I find there is no real prospect of success. Ground 10 alleges the possession order causes severe avoidable prejudice in the loss of the contract for sale, the £800,000 already paid, onward sale, the risk of sales at below market values and unjustly enriching SA, Bank of Scotland and Kiloran. There is no merit in this argument as I have already stated above. If there is any financial impact that can be by way of separate proceedings and does not in any event affect the Bank of Scotland’s rights under the terms of the charges. Ground 11 alleges the Judge wrongly refused permission to appeal, but there is no merit in this ground as the Judge’s finding has not restricted the rights to the hearing before me.[73]Mr Paton also submits that there are factual discrepancies in the agreed note of the judgment. Mr Paton states that paragraph 35 of the judgment states “I am then told that [the Appellants] paid another £150,000 which was paid to solicitors and then paid to [SA] without the restriction being lifted.” Mr Paton states that the variation of the contract of sale records that £740,000 was paid towards outstanding costs due to SA. It records that the total sum paid as £775,000 with the balance of £625,000 remaining outstanding and that there is therefore a discrepancy between the note of the judgment and the variation of the contract of sale in the sum of £590,000. Mr Paton also states that the Judge was in error in stating that £850,000 amounted to the loan agreement between Mr Paton and Mr Ben Paton and was paid to avoid imminent bankruptcy and was not tied to the property transaction. Mr Paton explained that the total loan advanced by Mr Ben Paton was in excess of £1 million secured against Miss Clutterbuck’s shares in Kiloran and the amended contract for sale. Mr Paton states that money was not part of the bankruptcy estate and undermined the Judge’s conclusion that any equitable interest “disappears” on bankruptcy and does not revert.[74]This note of judgment has not been approved by the Judge, but it has been agreed by the 2 professional representatives who were present at the hearing. It does appear that the reference to £150,000 is incorrect and that the loan agreement was in part used through the vehicle of the amended contract of sale and then onward payment by Kiloran to SA. However, if there are any such errors they make no difference to the outcome. They are part of the background, but they do not alter the analysis including that of any equitable interest or the question of bankruptcy (which I have dealt with at length above).[75]Mr Paton also raised an issue concerning the lack of a directions hearing in the Licence Proceedings. The difficulty with any argument he raised here is that he was a party to the consent order dated 17 April 2025, as he confirmed in court. This does not form any basis to grant permission to appeal. Mr Paton also argued that the Judge found that the defences to the First Proceedings were “quite substantive” and argued the Judge should therefore have considered them and were not properly evaluated on their merits as the sanctions decision was treated as determinative. As I have identified above, the Judge did use that phrase and described them as “relatively lengthy” but he concluded that they go no further than stating that Mr Paton and Miss Clutterbuck were licensees. For the reasons I have already given in dealing with Miss Clutterbucks grounds of appeal the Judge did consider this point sufficiently. I have dealt with the arguments on CPR55.8(2) and CPR 55.7(3) above.

Conclusion

[76]Conclusion For the detailed reasons I have given above, I find that in relation to the grounds of appeal of Miss Clutterbuck and Mr Paton there is no real prospect of success at an appeal. I have considered whether I should grant permission on part of ground 5 concerning CPR 55.8(2) (see paragraph 60 above), even if I dismiss the appeal, on the basis that the argument is a matter that amounts to some other compelling reason for the appeal to be heard. The Appellants could then consider whether to seek a second appeal on this point on which there is no authority. However, I do not consider that it does amount to such a justification as it would not be determinative unless there was a defence that had a real prospect of success, which there is not. I therefore refuse permission to appeal on all grounds for both Miss Clutterbuck and Mr Paton.[77]Summary Miss Clutterbuck and Mr Paton occupy 2 properties over which the Bank of Scotland has legal charges. Under those charges, the Bank of Scotland appointed receivers to bring proceedings to recover possession of those properties on the basis that Miss Clutterbuck and Mr Paton were trespassers. In defences to the First Proceedings, they both put in defences that they were licensees. The receivers then served notices terminating any licences and issued the Licence Proceedings to recover possession. Miss Clutterbuck and Mr Paton agreed to a date by which they would enter their defences to those proceedings and that date was extended by agreement due to Miss Clutterbuck’s ill-health. However, the defences were not served by the agreed deadline and applications for an extension of time and relief from sanction were made subsequently. The Judge below refused relief from sanction, found that there was no real prospect of a defence and made possession orders. I have refused permission to appeal that decision to both Miss Clutterbuck and Mr Paton and upheld the Judge’s order.

Postscript

[78]Postscript Having prepared the draft judgment for circulation to the parties, but before I had been able to send it to them, Mr Paton sent 2 emails on the 4 August 2026, one at 11.03 and the other at 23.25 hours. He sought to rely on Estate of Euan McIntyre Lindsay & Anor v Outlook Finance Ltd & Anor [2026] EWCA Civ 1005 and BlackBerry Limited v Optiemus Infracom Limited [2026] EWCA Civ 1004 and his supplemental notes on each case. I invited Mr Rothwell and Mr Fozlay to provide any submissions. Mr Fozlay had no comment to make and Mr Rothwell said that the authorities were not relevant and a delaying tactic.[79]In Blackberry Limited the issue was a decision not to strike out the case despite a 4-year delay and an application of the overriding objective to the particular circumstances. In such circumstances, there was no additional test of “compelling reasons”. In McIntyre Lindsay & Anor the case concerned an application to set aside a judgment obtained by fraud (there was another ground of appeal concerning laches). The principles the court found at paragraph 48 of Zacaroli LJ’s opinion were:
“First, in order to set aside a judgment on the grounds that it has been procured by fraud, it is necessary to show that the fraudulent evidence was that of the party against whom the judgment is to be set aside. Second, fraudulent evidence given by a witness for a party is not enough, unless the witness’ evidence is vital to the party’s case and the witness was an integral part of the litigation team. Third, in some circumstances it is appropriate to treat the fraud of party A as that of party B, for example because the two parties adopt a common cause in the proceedings and party B adopts the fraudulent evidence of party A for his own benefit (albeit without knowing it is fraudulent), in which case the judgment may also be set aside against party B.”
[80]Neither of these cases assist Mr Paton. In this case there is no finding of a relevant fraud or evidence of it. The only finding from the First-Tier Tribunal is that SA was from the Yemen and not Saudi Arabia as she had claimed. Mr Paton states it goes further than this to a false identity narrative. It is not necessary for me to set out the detail in this judgment. However, the cases provide no assistance over and above the cases to which I have already referred. They do not alter my decision.