Amar Lodhia v Twelve Trees (Bromley-By-Bow) Management Company Limited & Ors [2026] EWHC 1889 (KB)

[2026] EWHC 1889 (KB)Case No KB-2025-001785
IN THE HIGH COURT OF JUSTICE
KING'S BENCH DIVISION
MEDIA AND COMMUNICATIONS LIST
Venue Royal Courts of Justice, Strand, London, WC2A 2LLDate 24/07/2026
Before
MR JUSTICE LINDEN
Between
AMAR LODHIAClaimant(1) TWELVE TREES (BROMLEY-BY-BOW) MANAGEMENT COMPANY LIMITEDDefendant(2) URANG PROPERTY MANAGEMENT LIMITEDDefendant(3) MR THOMAS SQUIRESDefendant(4) MR ANDREW CREGANDefendant(5) MR TASLEEM MALLECK-AMODEDefendant
The Claimant appeared in person for in personJonathan Price KC and Percy Preston (instructed by rradar Limited) for First and Third-Fifth DefendantsGreg Lazarev (instructed by Lazarev Cleaves LLP) for Second DefendantAnthony Jones (instructed by Mills and Reeve) for Joseph ChiffersHearing Hearing dates: 14 and 15 July 2026
Approved JudgmentThis judgment was handed down remotely at 10.30am on 24 July 2026 by circulation to the parties or their representatives by e-mail and by release to the National Archives..............................MR JUSTICE LINDEN
[1]At a hearing which took place on 6 May 2026 (“the 6 May hearing”), I dealt with various issues in relation to costs following the discontinuance of the Claim by Mr Lodhia. For the reasons which I set out in a judgment handed down on 18 May 2026, under neutral citation number [2026] EWHC 1177 (KB) (“the 1st Judgment”), I decided that Mr Lodhia should pay the Defendants’ costs and he was ordered to make interim payments to them on account pursuant to CPR Rule 44.2(8): see my Order dated 18 May 2026.[2]However, certain issues were left over in relation to costs, namely whether any assessment should be on the indemnity basis, and the costs of the 6 May hearing itself. As at the date of that hearing, Mr Lodhia was also in breach of an Order of Steyn J dated 29 April 2026 (“the 29 April Order”) which she had made because there were concerns about the truthfulness of his evidence in support of an application to postpone the hearing which he had made, and the authenticity of documents on which he had relied for this purpose. The Defendants had also raised similar issues about other aspects of his evidence for the 6 May hearing.[3]I, too, was concerned about an N260 Statement of Costs (“the 5 May statement of costs”) which Mr Lodhia had submitted in support of his position that the Defendants should pay his costs. This declared that he was liable to pay c£82,000 in costs despite the fact that he said he was a litigant in person throughout the proceedings. This included a claim for £10,000 plus VAT in respect of the services of Mr Joseph Chiffers, counsel instructed on a direct access basis, whereas it was not clear what involvement in the case Mr Chiffers had had which was capable of justifying this figure. Mr Lodhia also told me in the course of the 6 May hearing that he had paid Mr Chiffers this sum, but it was not clear to me how he was able to do this given that he had said on various occasions that the Defendants would never recover their costs from him because he had no means and was on universal credit.[4]Accordingly, my 18 May Order gave directions for further evidence to be provided in relation to these matters and for the parties to set out their positions as to what steps should be taken in the light of this evidence. I granted certain extensions of time in relation to the deadlines in that Order including, on 3 June 2026, an extension of time (to 16 June 2026) for the parties to serve statements of their positions.[5]In the light of the evidence and submissions received, on 19 June I made an order (“the 19 June Order”) listing a hearing for 14 and 15 July 2026 (“the July hearing”) to consider the following issues, and I gave directions accordingly: i) Whether the orders against Mr Lodhia in respect of costs made on 18 May 2026 should be varied to provide that costs will be assessed on the indemnity basis, as the Defendants contended? ii) Whether Mr Lodhia should be ordered to pay the costs of the 6 May hearing itself, the basis for assessment and whether any further order for an interim payment on account of costs should be made against him? iii) The Defendants’ request that Mr Lodhia’s applications for postponements/a stay dated 19 February, 4 April, 29 April, and his application for permission to appeal, dated 18 May 2026, should be certified as totally without merit. iv) Whether a civil restraint order should be made against Mr Lodhia? v) Any application by the Defendants for wasted costs against Mr Chiffers (the Defendants other than the Second Defendant – “the TTMC Defendants” – having indicated that they might make one in due course). vi) Whether Mr Chiffers and/or Mr Lodhia should be referred to the appropriate regulatory body? vii) Whether proceedings for contempt of court should be initiated against Mr Lodhia? Although the Defendants contended that Mr Lodhia was guilty of contempt of court in various respects, for cost related reasons they were not themselves prepared to make a committal application. Their position was that the court should initiate contempt proceedings of its own motion or refer the matter to the Attorney General. viii) Any other application that was made before a deadline of 3 July 2026 which I set.[6]The Reasons which I set out in the 19 June Order stated in bold that Mr Lodhia should seek legal advice given that the allegations made against him – of doctoring the 29 April Order, of making multiple statements in his written evidence (verified by statements of truth) which he knew to be false, of exhibiting and/or relying upon fabricated or doctored documentary evidence, of knowingly filing false certificates of service, of knowingly making a false claim for costs in the 5 May statement of costs and of disobeying orders of the court - were very serious indeed. I then explained my Order, including what would and would not be considered in relation to the issues set out above. (There were allegations pleaded in proceedings in the Business and Property Court in 2021 (Claim No IP-2018-000157) that Mr Lodhia had fabricated evidence, which I said I would not determine for reasons of proportionality). Although I considered the issues to be clear, I explained them further in emails between my clerk and the parties in answer to points made by Mr Lodhia and Mr Chiffers, and in my Orders dated 10 June and 7 July 2026, which may be consulted for further context.[7]In the event, under [4(viii)], above: i) Mr Lodhia made applications dated 25 June 2026 and 3 July, and a second one dated 3 July which appears to have been submitted on 10 July 2026. These included applications for the evidence against him to be struck out, for the proceedings against him to be stayed pending his application for permission to appeal my Order of 18 May, for the question whether contempt proceedings should be initiated against him to be dealt with on a separate occasion, for the July hearing to deal with his argument that proceedings for contempt of court be initiated against Ms Emma Yates, one of the solicitors for the TTMC Defendants, and for him to be permitted to cross examine her. In the event, he withdrew these applications: in the case of the July applications, at midday on the second day of the hearing. I deal with them in more detail below but, in summary, I have found that they were an attempt to distract from his own misconduct, and his allegations against Ms Yates and other solicitors for the TTMC Defendants were totally without merit. ii) No application for wasted costs was made by the Defendants because, they said, Mr Chiffers had failed to clarify his role in the proceedings sufficiently. This is a matter which I consider below in relation to the question of the referral of Mr Chiffers to the Bar Standards Board. iii) There was an application by the Second Defendant to set off its liability to pay Mr Lodhia £840 on account of costs pursuant to an order made by Master Yoxall on 19 June 2026 in other proceedings (KB-2026-000549), against Mr Lodhia’s liability to pay the Second Defendant £3,600 on account of costs pursuant to my 18 May Order (“the set off application”).

SUMMARY OF MY CONCLUSIONS

[8]In this judgment I make detailed findings of fact for the purposes of determining the issues set out above. I have done so broadly in the order in which the areas of concern arose but, of course, I have considered each of these areas in the context of the evidence as a whole including Mr Lodhia’s written evidence and submissions, what he said to me at the hearings and my assessment of him based on what I saw. The fact that I do not mention a particular witness statement of his, or document which he has produced, or point which he made, does not mean that I have not taken it into account. I have applied the civil standard of proof, whereas proceedings for contempt of court require alleged contempt(s) to be proved to the criminal standard. Having made findings of fact, I have then applied the relevant legal tests and reached conclusions on the issues set out above.[9]In summary, I have concluded that: i) Mr Lodhia will be ordered to pay the costs of the 6 May hearing. ii) The assessment of the costs of the proceedings will be on the indemnity basis on the grounds of Mr Lodhia’s unreasonable conduct. iii) The Second Defendant’s set off application is refused. iv) Mr Lodhia has made several applications in the course of these proceedings which are totally without merit, namely: a) His application dated 19 February 2026 to postpone the May hearing (“the second postponement application”); b) His application dated 4 April 2026 to stay the proceedings (“the application for a stay”); c) His application dated 22 April 2026 to postpone the May hearing (“the third postponement application”); d) His application at the 6 May hearing for the hearing not to proceed on the grounds that his trustees in bankruptcy and/or his father had not been formally served with the proceedings; e) His 26 May 2026 application to me for permission to appeal to the Court of Appeal; f) His 25 June 2026 application for various matters; g) His 3 July 2026 application for various matters by way of an N244 application notice, which will be dismissed on withdrawal; h) His N600 application, on 3/10 July 2026, to commit Ms Yates for contempt of court, which will be dismissed on withdrawal. v) A General Civil Restraint Order will be made against Mr Lodhia which will apply for a period of 3 years; vi) Mr Chiffers and Joseph Chiffers Barrister at Law Limited will be referred to the Bar Standard Board; and vii) This case will be referred to the Attorney General’s Office for consideration of whether proceedings for contempt of court will be brought against Mr Lodhia and/or the matter should be referred to the police.[10]My decision to refer the matter to the Attorney General’s Office is based principally on my findings in relation to five areas of the case: i) First, I have found that in the context of the third postponement application Mr Lodhia relied on fabricated or doctored documents and submitted witness statements containing false evidence to support his application. He then doctored an order of the court – the 29 April Order – and he subsequently gave false evidence to the court, in witness statements verified with statements of truth, seeking to explain his actions. ii) Second, Mr Lodhia fabricated various letters of claim and submitted false N215 certificates of service of those letters in order to support an argument that the Defendants should pay the costs of an application made by them and/or the proceedings and/or he should not be ordered to pay costs. Again, he has since provided false explanations of his actions in witness statements verified by statements of truth. iii) Third, Mr Lodhia misrepresented the position of his trustees in bankruptcy, Begbies Traynor Group, in relation to these proceedings and manipulated the evidence to do so, including in witness statements verified with a statement of truth. iv) Fourth, I have found that Mr Lodia’s declaration, in the 5 May N260 Statement of Costs, that he was liable to pay c£82,800 in costs, including £10,000 plus VAT to Mr Chiffers, was untrue. These were costs which he was seeking to recover from the Defendants on a false basis. He also lied to the Court at the hearing on 6 May when he said that he had paid Mr Chiffers’ fees, and he has since provided explanations, in witness statements verified with statements of truth, which are false. He has also submitted other statements of costs in the course of the proceedings which appear to make false claims. v) Fifth, the explanations for his conduct which Mr Lodhia has provided were in witness statements made in response to orders of the court and there are instances of him failing to comply with orders of the court in any event. BACKGROUND The parties

BACKGROUND

[11]The background is set out in more detail in the 1st Judgment. For ease of reference, however, Mr Lodhia describes himself in his Particulars of Claim as “a respected legal consultant, social entrepreneur, and public interest advocate, widely known for his work on housing rights, legal reform, and community empowerment”. He is also a leaseholder at the Maltings residential estate in Bow, East London (“the Maltings”) and, he says, the elected Chairman of Maltings Close Residents Association and the appointed legal representative of Maltings Close Residents Management Company Limited, as well as 23 leaseholders, in an application to review the reasonableness of service charges at the Maltings. He is the founder of the “Fighting Injustice” campaign and he says that he is insured to provide legal consultancy services and has obtained multiple six figure settlements in “pre-action litigation”. He works as a “supervised legal consultant” at JSC Chambers whose Head of Chambers is Mr Chiffers.[12]Mr Lodhia is currently undertaking a post graduate law course at the University of Law in London, although he told me at the July hearing that he had decided to move to the University of London as a result of a breakdown in key relationships with the University of Law in circumstances which I describe below. He intends to become a barrister and, on 4 June 2026, was admitted as a member of the Inner Temple. It is also apparent from the evidence that, apart from providing legal services in his role at JSC Chambers, he has conducted a number of cases as a party, has been involved in litigating on behalf of others and has appeared as an advocate in that context.[13]Mr Lodhia confirmed to me, when I asked, that a civil restraint order had been made against him in the past. The record shows that this was a 2 year General Civil Restraint Order (“GCRO”) which was made by Collins Rice J on 4 November 2022 on the grounds that he had persistently made claims or applications which were totally without merit. The GCRO applied to claims and applications brought by him directly or through “Fit Kitchen Ltd”, of which he was a director, in various claims involving Islington Borough Council in London. It was based on 9 applications which he and/or Fit Kitchen Ltd had made in the County Court, the King’s Bench Division and the Administrative Court which were totally without merit. Mr Lodhia was ordered to pay the costs of the application for the GCRO in the sum of £8,409.[14]Mr Lodhia is also subject to a bankruptcy order which was made on 10 June 2024 following a bankruptcy petition which was issued by Shakespeare Martineau LLP on 11 November 2022. His trustees in bankruptcy are Constantinos Pedhiou and Amie Johnson of Begbies Traynor Group (“the Trustees”).[15]As for the Defendants: i) The First Defendant (“TTMC”) is the corporate entity through which the Maltings is managed. ii) The Second Defendant (“Urang”) is the property management services company engaged by TTMC to provide relevant services at the Maltings. iii) The Third, Fourth and Fifth Defendants are residents of the Maltings and directors of TTMC.[16]I will describe the Defendants other than Urang as the TTMC Defendants. At all material times their solicitors in these proceedings were rradar Limited (“rradar”) and Ms Yates and Ms Klaudia Matusiewicz had the conduct of their case. The proceedings[17]Proceedings were issued by Mr Lodhia on 15 May 2025. In his original Particulars of Claim, dated 25 March 2025, he sought damages for defamation and malicious falsehood against each of the five Defendants in relation to 11 statements made in a TTMC letter to leaseholders of the Maltings dated 6 March 2025 (“the Newsletter”) which was written by the Third Defendant (“Mr Squires”) and sent out by Urang. The Newsletter criticised Mr Lodhia’s litigation and other activities in relation to the Maltings and accused him of lying and making baseless allegations against TTMC and false promises to residents. It said that he was currently bankrupt, had no formal legal training, and had previously been the subject of a general civil restraint order in relation to vexatious litigation against Islington Council. And it encouraged leaseholders to seek independent legal advice before acting on Mr Lodhia’s recommendation to refuse to pay their service charges.[18]The Defendants applied for summary dismissal of aspects of Mr Lodhia’s claim (“the summary disposal application”) on 15 July 2025, and subsequently for a trial of preliminary issues as to the meanings of the statements in the Newsletter which were complained of by Mr Lodhia for the purposes of his claims in defamation. By order dated 13 November 2025, Steyn J listed the summary disposal application and a trial of the preliminary issues for hearing on 21 and 22 January 2026 (“the January hearing”).[19]However, on 11 January 2026, without warning Mr Lodhia then applied to amend his Particulars of Claim to abandon any claim against the Fourth and Fifth Defendants and his claims in malicious falsehood against the other Defendants. In effect this conceded the summary disposal application which, up until this point, he had repeatedly maintained was “misconceived”. His proposed amendments also narrowed the scope of his defamation claims against the First to Third Defendants so that they were now based on six statements made in the Newsletter.[20]On 15 January 2026, Mr Lodhia then successfully applied to postpone the 21 and 22 January hearing (“the first postponement application”).[21]On 16 February 2026, a trial of preliminary issues as to meaning in relation to the six statements complained of, and a hearing for the determination of issues in relation to costs was listed for 6 and 7 May 2026 (“the combined hearing”). However, on 19 February and 4 April 2026 respectively, Mr Lodhia applied for a postponement of that hearing and then for a stay of the proceedings. Both applications were refused by order of Steyn J dated 17 April 2026 (“the 17 April Order”).[22]Mr Lodhia made a further application for a postponement of the combined hearing on 29 April 2026 on the basis, he said, that this clashed with University of Law oral assessments which he had on both days of the hearing, of which he had first become aware on 21 April 2026. This resulted in the 29 April Order in which Steyn J expressed concerns about the about the truthfulness of what were by then Mr Lodhia’s 10th and 11th witness statements, on which he relied in support of that application, and about the authenticity of certain documents exhibited by Mr Lodhia to prove that the alleged oral assessments clashed with both days of the combined hearing. She therefore made directions for further evidence in order to address those concerns, including a further witness statement from Mr Lodhia and a witness statement from the University of Law.[23]What happened thereafter, and the events leading up to the hearing on 6 May are dealt with in more detail below under the heading “the third application for a postponement”. THE JULY HEARING[24]By the time of the July hearing, we had reached witness statement number 26 from Mr Lodhia, which was dated 3 July 2026. In addition, there were “updated” versions of some of his statements where he amended the statement to respond to evidence which had emerged, and there was a witness statement made by his father dated 20 May 2026. Since 6 May my clerk had also received multiple emails from Mr Lodhia, sometimes several in a day, despite my efforts, in my 19 June Order and through my clerk’s emails, to discourage attempts by him to score points and to argue the case before the hearing. This greatly and unnecessarily added to my clerk’s burden and, on a number of occasions, wasted the time of the court and the other parties.[25]There were various other witness statements before the court, including six from Mr Chiffers (including one which was an amended version of his 2nd witness statement) purporting to deal with his involvement in these proceedings. In addition to these there were two statements from Dr Myrto Tsakopoulou of East London NHS Foundation Trust, and one each from Ms Saloumeh Verrell, a Senior Lecturer at the University of Law (dated 15 May 2026); and Ms Kerri Cramphorn, a Senior Insolvency Manager at Begbies Traynor Group (dated 9 June 2026). Dr Tsakopoulou had been ordered to provide her statements because there were concerns about the authenticity of certain documents which Mr Lodhia presented as having been prepared by her. Ultimately, in the light of her evidence, this issue was not pursued by the Defendants. I am grateful for her assistance, and for the assistance of Ms Verrell and Ms Cramphorn.[26]On the Defendants’ side, reliance was placed on the witness statements which were before the court at the 6 May hearing, and the 8th witness statement of Ms Yates which is dated 16 June 2026. As I noted in my 19 June Order, this helpfully set out the Defendants’ allegations against Mr Lodhia, taking into account the evidence which had been provided since the 6 May hearing. My Order also identified other issues which I wished to consider.[27]In the run up to the hearing, Mr Lodhia made various email attempts to persuade me that, before the hearing, I should determine his applications to exclude some or all of Ms Yates’ evidence in her 8th witness statement. At the same time, he applied to cross examine her at the hearing and said that he was also applying to cross examine Ms Matusiewicz, ostensibly on the basis that he alleged that they were guilty of professional misconduct and as part of his case that Ms Yates should be committed for contempt of court. Although Ms Matusiewicz was on leave, he went as far as to request that she be required to attend remotely for these purposes, and to say that if I refused this I should record my reasons in a sealed order so that there could be an urgent application to the Court of Appeal before the July hearing. I indicated that these matters would be considered at the hearing itself.[28]Mr Lodhia’s position was also that, at the hearing, he should make his submissions first on the basis that he was seeking to exclude the evidence against him. The thinking seemed to be that this would then negate the case against him and/or that if I refused the application he could then appeal and seek a stay pending the outcome. I indicated more than once by email, in advance of the hearing, that my provisional view was that I should hear all of the evidence and all of the arguments on all sides before deciding what orders to make. Moreover, the fairest approach was for the Defendants to present the case against Mr Lodhia so that he and then Mr Chiffers could respond with the best possible understanding of the criticisms of them which were being made. That was the course which I took at the hearing.[29]In the 1st Judgment I noted that Mr Lodhia describes himself as disabled and vulnerable. At the July hearing he relied on the medical evidence which was before the court on 6 May. This took the form of “to whom it may concern” letters from Dr Tsakopoulou. She was, at the material times, a Complex Emotional Needs and Complex Trauma Lead Psychologist and Mr Lodhia was undergoing a course of treatment with her which, he told me, came to an end in mid-April 2026. In her letters she said that Mr Lodhia has complex post-traumatic stress disorder and was receiving treatment from her for complex trauma. She considered that he had a disability for the purposes of section 6 of the Equality Act 2010. On 17 July 2025, she said that, by way of reasonable adjustments to these proceedings, Mr Lodhia would need information to be shared in a clear and concise manner, and communication to be slowed down so as to ensure that he understands. He would need breaks if he became overwhelmed and (per a separate letter which Mr Lodhia sent to rradar on 11 September 2025) breaks of 20-30 minutes every 90 minutes or so in any event. Dr Tsakopoulou also implied that Mr Lodhia has “difficulties with concentration, information processing, and managing stress in high-pressure environments”.[30]I have also taken into account the evidence of adjustments which have been made by the University of Law under the genuine version of its “University of Law Inclusion Plan” (“ULIP”). This does not directly reveal any significant additional information about his condition(s), but the adjustments are consistent with the evidence of Dr Tsakopoulou with which I have been provided. As at the 6 May hearing (i.e. some time after Dr Tsakopoulou’s letters), I saw no sign of the difficulties described by Dr Tsakopoulou (see 1st Judgment at [35]) in either his written work or his oral submissions and responses to Mr Price KC’s submissions or the Court’s questions. He also produced lengthy and detailed documents remarkably rapidly (albeit this may well have been with the assistance of AI) and he showed considerable ingenuity and agility, both orally and in writing, in attempting to explain the evidence against him. I will, however, assume for present purposes that his difficulties persisted at the time of the events under consideration in this case and, indeed, at the July hearing.[31]Accordingly, we took breaks in the middle of each court session at points which were convenient to Mr Lodhia. I also put the key concerns which were under consideration to him in the course of the hearing, and I made sure that he had fully understood the points which were being made against him. He was given every opportunity to add to his responses to these points, having already set his position out in writing in his witness statements and in his written submissions. My Order of 19 June made clear that Mr Lodhia could supplement his written evidence by giving oral evidence at the July hearing if he wished. He confirmed at the beginning of the hearing, however, that he was not seeking to do so although he said he was willing and able to do so if necessary.[32]Mr Chiffers did not attend the hearing. This came as a surprise to me. Mr Jones told me that Mr Chiffers is “a busy man” and “has other commitments”. The only evidence I had about this was that Mr Chiffers had said in his 3rd witness statement, dated 3 July 2026, that he might be unable to attend the hearing and that he was scheduled to appear at the hearing of an application to amend a client’s Particulars of Claim on the second day of the hearing. He did not say where the other hearing was taking place, and his 5th statement says that it was taken out of his diary at 10am on the first day of the July hearing.[33]In his 3rd statement, Mr Chiffers also commented that he did not believe that he would receive a fair hearing for the reasons which he had set out in an application to vary the 19 June Order (which I refused), and in his application to the Court of Appeal for permission to appeal against that Order and for a stay pending his appeal. By the time of the July hearing, both applications had been refused by the Court of Appeal. I was also informed on the morning of the hearing that Mr Lodhia’s application for permission to appeal against my 18 May Order had been refused.[34]I had a concern about the lack of detail in Mr Chiffers’ various witness statements, which I had expressed by email in the run up to the July hearing, and in my Orders of 10 June and 7 July 2026. On the first morning of the hearing I therefore sent out, by email, a list of questions which I was likely to ask at the hearing about his position in relation to documents in the bundle which I identified. When I was told at the beginning of the hearing that Mr Chiffers was not attending, I confirmed with Mr Jones that he was fully instructed and had had all of the bundles etc. He replied in the affirmative and said that he would also be able to take instructions on my questions, and would answer them in his oral submissions which were scheduled to take place on the second day of the hearing, after Mr Lodhia had given his account of Mr Chiffers’ involvement in the case.[35]In the event, Mr Jones helpfully dealt with my questions. He did so carefully and on the basis of his instructions, for which I am grateful. Given that there was significant divergence between Mr Chiffers’ account and that of Mr Lodhia, and given the importance of the issues to both, I considered that Mr Chiffers should set out his instructions to Mr Jones in a further witness statement, and Mr Jones told me that Mr Chiffers was willing and able to do this by 4pm on Friday 17 July. Mr Lodhia did not seek to respond to what the court had been told by Mr Chiffers through Mr Jones, but I offered him an opportunity to do so by way of a witness statement in any event. He said that he would do so by 4pm on Monday 20 July 2026.[36]Mr Chiffers duly proved his 5th witness statement dated 17 July 2026, and Mr Lodhia provided his 27th witness statement, dated 20 July 2026. This runs to 13 pages with 181 pages of exhibits. It goes significantly beyond replying to Mr Chiffers’ statement but I have nevertheless taken all of it into account bearing in mind the importance of the issues which it addresses. THE SECOND POSTPONEMENT APPLICATION AND THE APPLICATION FOR A STAY OF THE PROCEEDINGS

Context

[37]The second postponement application and the application for a stay should be considered in the context of Mr Lodhia’s first application for a postponement. I dealt with the first postponement in the following paragraphs of the 1st Judgment: [8], [74] and [117]-[118]. The second application to postpone, and the application for a stay, are dealt with at [75]-[78].[38]As noted above, on 13 November 2025 the summary disposal application was listed for combined hearing with the trial of preliminary issues for 21 and 22 January 2026 by order of Steyn J. Until his application on 15 January 2026, the basis for Mr Lodhia saying that a postponement was required was the non-availability of his counsel of choice: Mr Chiffers. Before this, Mr Lodhia did not mention the need to attend hospital although the Defendants say that he must have been aware of it in December. The application was granted by order of Collins Rice J on Monday 19 January 2026, essentially on the grounds that there was evidence that Mr Lodhia had a medical appointment which clashed with the second day of the hearing.[39]In concluding that Mr Lodhia was liable to pay the costs of the first postponement application I found that: i) His/JSC Chambers’ emails of 22 December 2025 first proposed the postponement on the grounds that, that day, he had instructed Mr Chiffers who was not available for the hearing. Insofar as that was the true reason for his application to postpone, it was an unreasonable basis, and the Defendants were fully entitled to refuse to agree. ii) Even taking Mr Lodhia’s evidence about the medical appointment at face value, his application succeeded on a ground which was introduced very late in the day. The Defendants’ skeleton argument for the hearing had been filed on 14 January and, as Collins Rice J noted, preparations were necessarily well advanced at this stage. Substantial costs had therefore been incurred by the Defendants.

The second application to postpone

[40]On 12 February 2026, there was a listing appointment to relist the adjourned January combined hearing. Mr Lodhia failed to attend, and the hearing was relisted for 6 and 7 May 2026.[41]On 19 February 2026, Mr Lodhia made a second application to postpone what was now the May hearing on the grounds that Mr Chiffers was not available. In a letter to the court on JSC Chambers notepaper, which was purportedly from JSC Chambers, Mr Lodia wrote:
“Counsel is already fully apprised of the case, He has read into the pleadings, evidence and interlocutory history, and has been engaged in strategic preparation. The suggestions that the Claimant should simply instruct alternative counsel – as was expressly proposed by Ms Yates – disregards both the financial and practical realities. To instruct new counsel at this stage would require: • A complete re-reading of pleadings, witness evidence and interlocutory history; • Familiarisation with complex procedural disputes; • Re-preparation for a preliminary issue trial on meaning; • Additional conferences and drafting. The cost of reinstruction would not be incidental. It would likely run to may thousands – potentially tens of thousands – of pounds, once proper allowance is made for new counsel to read into a complex High Court matter that has already generated substantial interlocutory history. For a vulnerable disabled litigant, that burden is neither proportionate nor realistically sustainable. It would arise solely because the Defendants refuse to accommodate a short and reasonable adjournment.”

To instruct new counsel at this stage would require:

[42]This application notice was signed by Mr Lodhia and the name of his “firm” was given as JSC Chambers. In his witness statement in support of the application (his 7th witness statement), which he signed to confirm that he believed the facts stated to be true, Mr Lodhia repeated these claims, including that he had instructed Mr Chiffers on a direct access basis. He said that Mr Chiffers had:
“(a) read into pleadings and witness statements; (b) reviewed interlocutory history; (c) considered amendment issues; (d) advised on meaning and costs; (e) prepared strategically for the preliminary issue trial.”
[43]Since the 1st Judgment, Mr Chiffers has been specifically asked about these claims in a letter from rradar dated 2 July 2026. He was pressed about his involvement in a further rradar letter on 7 July, and I pointed out the relevance of these questions in my Order of 7 July 2026. Notwithstanding this he has failed to reply to the rradar letters on this subject and his evidence on this point has been vague. I summarise his evidence below in the sections on Mr Lodhia’s 5 May statement of costs and referral to the regulator. But, in short, in the light of Mr Chiffers’ evidence I find that Mr Lodhia was significantly exaggerating the amount of work which Mr Chiffers had undertaken at this point, and which would be wasted if he were not to appear at the May hearing. Nor is it clearly established on the evidence that Mr Chiffers was in fact unavailable for the May hearing or, indeed, for the whole of May as Mr Lodhia had represented. In relation to these issues see, further, Ms Yates’ 4th witness statement dated 24 February 2026. The application for a stay[44]On 4 April 2026, Mr Lodhia then issued an application to stay the proceedings until 30 September 2026, purportedly so as to facilitate mediation, and for the May hearing to be vacated. Again, the application notice was signed by him and the name of his firm was given as JSC Chambers. The application was supported by his 9th witness statement (dated 4 April 2026) which included a full statement of truth.[45]In his 9th statement Mr Lodhia argued, amongst other things, that the second day of the combined hearing was reserved to deal with the question of costs (which was not in fact the case), that a costs hearing was premature at this stage and that, in any event, there was “no realistic prospect” of a costs order in the Defendants’ favour “because of the Defendants’ failure to respond to the Claimant’s letter of action of 7 March 2025 – in which they were asked to provide details of the author, publisher and editor of the defamatory publication..”. I deal with this and similar claims made by Mr Lodhia below in the section of this judgment which deals with the March letters of claim but, in short, I am satisfied that he had not sent the 7 March letter of claim to which he referred.[46]Mr Lodhia argued in favour of a mediation which, he said, Mr Chiffers should attend on the basis that “The Claimant is represented at JSC Chambers by Mr Joseph Chiffers, Barrister, who acts as supervising counsel”, and Mr Chiffers was on the record in First Tier Tribunal proceedings against TTMC which would also be the subject of the proposed mediation. He said that Mr Chiffers was unavailable until July. He then returned to a set of submissions that “The circumstances clearly favour the grant of a stay of these proceedings, including of the costs hearing listed for 7 May 2026”. It is apparent from his witness statement that he was keen that what was the second day of the combined hearing should not go ahead. In my view this is relevant context for his (third) application to postpone, later in April, which I deal with in more detail below.[47]I also note that Mr Lodhia exhibited a N260 Statement of Costs to his 9th witness statement. This was dated 4 April and it claimed that he was liable to pay £10,017.50 plus VAT in fees in respect of the application for a stay. This included £750 to Mr Chiffers in respect of “advice/conference/documents”, equating to 3 hours’ work. There are various problems with this claim, and these are discussed below. But, in short, it was not the case that he was liable to pay the sums claimed.[48]The second postponement application and the application for a stay were refused by Steyn J on 17 April but she said that if the parties agreed that the time estimate for the combined hearing could be reduced to one day it could be listed accordingly. The hearing would otherwise remain listed for 6 and 7 May 2026. Steyn J’s Reasons included the following:
“A. The Defendants’ applications for summary disposal and for a trial of preliminary issues were…initially listed for hearing on 21 and 22 January 2026, after extensive efforts to obtain dates of availability from the Claimant who took what I described, in my order of 13 November 2025, as an unacceptable approach in seeking a hearing in July 2026. B. On 15 January 2026, the Claimant made his first application to vacate in respect of the hearing that was then only a few days away….. In her order, Collins Rice J made clear that the parties “must co-operate to ensure that the adjourned Combined Hearing is brought back into the list as soon as reasonably practicable” and that the availability of the Claimant’s direct access counsel, Mr Chiffers, was to be accommodated “provided that no unwarranted delay is introduced as a result”
. C. Despite the terms of that order, the Claimant failed to attend the listing appointment, expressly declining the invitation. He has no reasonable excuse for failing to attend. The appointment was re-listed, to suit him, when the initial timing was such that he was unavailable. The first excuse that he has given is that the Defendants had not accepted the diary invitation. It was not reasonable to assume that they were not going to attend, and in any event, the Claimant should have attended irrespective of whether he thought any other party might fail to attend. The second excuse the Claimant has given is that he was waiting for clarification of whether the hearing will be one day or two. Collins Rice J’s order made clear that the two day hearing was to be re-listed. She noted the possibility that the length of the hearing may be reduced, but that possibility did not justify the Claimant’s failure to attend the listing appointment. D. As the Claimant failed to attend the listing appointment, the Combined Hearing was listed in his absence. However, I note that on 19 January 2026 the Claimant wrote, “Our instructed counsel is not available until the first week of May. We will, once counsel has confirmed availability, provide proposed dates between May and July. Please note that counsel will be attending with me and that we will both be advocating.” Although the Claimant has alleged that prior to the 6 and 7 May hearing being listed he had identified that his direct access counsel, Mr Chiffers, would be unavailable in May, there is no evidence to that effect. On the contrary, the Claimant had expressly said he was not available “until the first week of May”, and the Combined hearing has been listed in that week. E. The Claimant seeks an adjournment on the basis that Mr Chiffers is unavailable on 6 and 7 May. I am not prepared to grant such an adjournment. There has already been substantial delay and I am not prepared to delay the hearing of the Defendants’ applications yet further. The Claimant has had plenty of time, if he wishes, to instruct alternative counsel. It may be that will add some cost but there is no cogent evidence of Mr Chiffers having undertaken a substantial amount of work on this case. None of the pleadings or skeleton arguments are in his name, and he was instructed on 22 December 2025 in the knowledge that he was unavailable for the hearing that had been listed for 21 and 22 January 2026. It is unlikely he undertook any significant amount of work for that hearing, which he was never intending to attend. In any event, the Claimant took the risk that he would have to bear the additional cost of instructing alternative counsel when he instructed Mr Chiffers despite his unavailability for the listed hearing. Alternatively, the Claimant may choose to represent himself. It is apparent that he was always intending to do so, at least in part, even if Mr Chiffers was available. The issues are not particularly complex. The meaning trial is effective. It appears that the Summary Disposal has been rendered obsolete by the Claimant’s (unopposed) application to amend. So the only other issue will be costs. Those are all matters that alternative counsel or the Claimant would be able to deal with without any particular difficulty.”[49]Steyn J specifically rejected Mr Lodhia’s contention that the hearing of any costs applications should be vacated.[50]As far as the 4 April application for a stay is concerned, Steyn J noted that the Defendants were willing in principle to engage in mediation but said that a stay would be contrary to the overriding objective. There was “no good reason to put the proceedings on hold for more than 5 months because of the possibility of settlement” and, indeed, the determination of the issues as to meaning would be likely to assist the process of settlement. Conclusion[51]I accept that both the second postponement application and the application for a stay were totally without merit for the reasons identified by Steyn J in refusing these applications, and taking into account the additional evidence, since her 17 April Order, which I have seen. In short, these applications were part of a pattern of seeking to avoid the May hearing notwithstanding that there were no grounds to postpone it. THE THIRD APPLICATION FOR A POSTPONEMENT

Analysis of the evidence

[52]I dealt this topic at the following paragraphs of the 1st Judgment: [83]-[91] and [116]-[118]. Since the 1st Judgment, Ms Saloumeh Verrell (Programme & Student Lead (Law Conversion Programme) at the University of Law) has filed a witness statement dated 15 May 2026. My findings in the light of her evidence and the evidence and submissions of Mr Lodhia, including his 27th witness statement, are as follows.[53]Mr Lodhia’s Assessment Timetable was available to him from September 2025. It stated that his contract law assessment was scheduled for 7 May 2026. This did not involve an oral assessment. The criminal law assessment did, and the Assessment Timetable notified him that this would take place in the window 27 April to 15 May 2026.[54]On 17 April 2026, Mr Lodhia wrote to rradar, referring to Steyn J’s Order of that date and proposing that the combined hearing be reduced to a single day: 6 May.At 1:25pm on 20 April he then wrote to the court with this proposal, and he enclosed a proposed timetable for the proposed one day hearing on 6 May. Although Mr Lodhia denied this when I asked him, it appeared that his continuing argument that the hearing could be dealt with in one day, and that this should be 6 May, was because he had a contract law assessment on 7 May but did not feel that he could rely on this to get a postponement because he had known of it for some time and had not raised it before.[55]At 2.01pm on 20 April, the Assessment Office of the University of Law notified Mr Lodhia by email of the timing of his upcoming criminal law oral assessment in bold as follows:
“Date – 12/5/2026 Time – 6:00:00 PM”
Time – 6:00:00 PM”[56]A link was provided as the assessment was to take place remotely.[57]The email also said that oral assessments were final and fixed but that if the student was unable to attend they should consult the “Extensions, Deferrals and Mitigating Circumstances (EDMC) and Stage One Appeals section of the Assessment Overview”.[58]At 2.27pm on 20 April, Ms Verrell emailed Mr Lodhia as follows:
“You also should have your criminal oral date and time now. Please confirm……I have looked at the online TT and can see your oral is on Tue 12/5/26 18:00-18:45 with H Uglow”
[59]At 2:42pm Mr Lodhia replied, directly below this paragraph: “Yes I have received this”.[60]I am therefore quite satisfied that, at all material times from this point, Mr Lodhia was aware that his criminal law oral assessment did not clash with the May combined hearing at all. He had also always known that there was no oral contract law assessment. He did, however, know that he had a contract law written exam on 7 May. These are important points when evaluating his subsequent conduct and his explanations for that conduct.[61]Notwithstanding this, under cover of an email at 9:20am on 22 April 2026 (signed “Yours faithfully JSC Chambers”) Mr Lodhia sent rradar a letter from JSC Chambers dated 21 April. This began “We write on behalf of the Claimant” and it sought agreement to vacate the May hearing on the basis that Mr Lodhia had exams. The letter falsely stated that Mr Lodhia “only became aware of the listing of his assessments for 6 and 7 May 2026 upon accessing his university email account on the evening of 21 April 2026” and that:
“3. Critically, 6 and 7 May 2026 are examination and oral assessment dates within the Claimant’s PGDL/MA Law programme at the University of Law, London Moorgate. Specifically: a. 6 May 2026: Criminal Law oral assessment (reasonable adjustments schedule), 12:00 PM – 2:00 PM; and b. 7 May 2026: Contract Law oral assessment (reasonable adjustments schedule), 9:00 AM – 12:00 PM. These assessments are fixed and non-deferrable as a matter of university regulations save through formal mitigating circumstances processes. They form part of the Claimant’s final-year assessed curriculum. The Claimant is not in a position to attend a two-day High Court hearing and simultaneously comply with his assessed university obligations, including revision and the cognitive overload he is likely to be faced with on those dates. Attendance at the Combined Hearing would require the Claimant to miss or fail these assessments, with potentially irremediable academic consequences.”
(emphasis added) a. 6 May 2026: Criminal Law oral assessment (reasonable adjustments schedule), 12:00 PM – 2:00 PM; and b. 7 May 2026: Contract Law oral assessment (reasonable adjustments schedule), 9:00 AM – 12:00 PM.[62]The 21 April JSC Chambers letter also stated that Mr Lodhia was represented by “JSC Chambers (Joseph Chiffers Barrister at Law Limited)” and that counsel was unavailable for the hearing on 6 and 7 May. It enclosed: i) A draft N244 application notice dated 22 April 2026 which bore Mr Chiffers’ signature and which included the false claims, in Box 3, that Mr Lodhia “now has final year assessments on both days” and that he had only become aware of this on the evening of 21 April. This claim was repeated at [5] of Box 10 and [6] stated that a response to the JSC letter of 21 April was awaited. I note that Mr Chiffers’ evidence is that this is his electronic signature but that he has no recollection of affixing it to that document or authorising anyone else to do so. Nor does he recall seeing this document or any of the supporting materials for the application which was made. He says that he cannot see any record of him reviewing the application. Mr Lodhia told him that he himself would be applying to adjourn the hearing and Mr Chiffers cannot exclude the possibility that they discussed its wording, although he has no recollection of doing so. Mr Lodhia’s evidence, in his 27th witness statement, is that he did not place Mr Chiffers’ signature on the application and did not have the ability to do so. He says he cannot remember “the mechanics” but is it is likely that he asked Mr Chiffers’ assistant, Tracey Johnson, to help him in filing the application notice. ii) An email of 20 April 2026 which, on its face, was from the Assessment Office of the University and which verified the account in the JSC letter of 21 April. Under the heading “Criminal law – Reasonable Adjustments Oral Assessment” the email stated that the assessment was on 6 May 2026 at 12 to 2pm. It also stated, under the heading “Contract Law – Reasonable Adjustments Oral Assessment” that this would take place between 9am and midday on 7 May 2026. Links were provided on the basis that the assessments would be conducted remotely. It is now clear that this was a doctored version of the email which had actually been sent to Mr Lodhia by the Assessment Office on that date notifying him that his criminal oral assessment was on 12 May 2026. The doctored email retained the rubric in relation to the EDMC process which appeared in the original (true) version.[63]At 12:48 on 22 April, a little over 3 hours later, Mr Lodhia chased for an answer to his email. He then sent a detailed request for specific disclosure on JSC Chambers headed notepaper dated 22 April, copying in Mr Chiffers. A reply was required by 28 April, and it was said that an application to the court would be made unless there was a satisfactory response.[64]At 10:48 on 23 April 2026, rradar emailed Mr Lodhia and Mr Chiffers (given that he had signed the application notice and was copied in on the 22 April JSC letter) to say that they did not consent to a postponement of the combined hearing. Unsurprisingly, they questioned whether Mr Lodhia could have been notified of the timing of his assessments (plural) as late as he said, and they said that, in the event that an application to the court was made, they would expect his evidence to set out fully how those assessments came to be arranged. They also noted that, in any event, there was a process available to defer them and said that they would expect him to evidence any attempts to defer which had been made.[65]Mr Chiffers did not reply to the rradar email. However, 17 minutes later Mr Lodhia replied, saying that the Defendants’ objection was “misconceived” and “we intend to file the application in due course”. Mr Lodhia also said that “we will be seeking the costs of the application, including costs on the indemnity basis….”. This aggressive/high handed response was characteristic of his approach to the proceedings (see, also my findings in the 1st Judgment) and, when the true position in relation to his application is appreciated, it aggravates his conduct.[66]Mr Lodhia also said:
“For the avoidance of doubt, the Claimant met with the University yesterday to discuss this issue. At that meeting, the University confirmed that the matter does not fall within the ERDM categories.”
[67]This purported to address rradar’s point that (as the 20 April email and the JSC letter of 21 April both indicated) there was a process available to defer the assessment, and that they would expect there to be evidence that Mr Lodhia had attempted to defer. As will be seen, in his 10th witness statement Mr Lodhia built on his claim that he had met with the University on 22 April to try to rearrange the assessments and had been told that this was impossible. However, what he said in this email and in his 10th witness statement was also untrue.[68]Mr Lodhia’s ULIP was updated on 1 April to make certain adjustments to the oral criminal law assessment, and sent to him on 24 April 2026. At 3.13pm that day, Mr Lodhia/JSC Chambers emailed rradar to say that an application had been filed and would be served when sealed. (He subsequently said that it was filed on 25 April 2026 and again threatened indemnity costs: see his email of 27 April 2026 at 5.01pm.). The sealed application notice does not appear to have been served on the Defendants until 29 April.[69]Steyn J’s Order of 29 April records that the application notice dated 22 April was filed on the 29th, although nothing turns on this. This application was supported by Mr Lodhia’s 10th witness statement, which is dated 24 April. The statement explained that he had a recognised cognitive disability and had a University of Law Inclusion Plan which had most recently been updated on 24 April. On the evening of 21 April 2026, he had been notified for the first time that his scheduled assessments were as follows:
“(a) 6 May 2026: Criminal Law — Reasonable Adjustments Oral Assessment, 12:00 PM to 2:00 PM (with 100% additional time as provided in my ULIP); and (b) 7 May 2026: Contract Law — Reasonable Adjustments Oral Assessment, 9:00 AM to 12:00 PM (with 100% additional time as provided in my ULIP).”
[70]He went on to say that “These assessments have been specially designed to accommodate my cognitive disability. My ULIP (updated 24 April) records under Section 5A that both exams have been converted into oral examination format in substitution for any written or on-screen examination”. In other words, his evidence included that the criminal law assessment had previously been a written one and that he no longer had a written contract law exam. Neither of these statements was true. He went on to provide a detailed explanation of why this was necessary and to draw further attention to the requirements of the ULIP in this regard. It is another aggravating feature of this case that he sought to rely on his disability and his rights under the Equality Act 2010 as part of a (false) explanation of why he was being assessed orally when, in fact, his disability had nothing to do with whether his assessments were oral or written.[71]At [8] and [9] of his 10th witness statement Mr Lodhia said this:
“8. On 22 April 2026, I attended a meeting with the University of Law Programme Lead, Salome Verrell. The purpose of that meetingwas specifically to explore whether the assessments listed on 6 and 7 May 2026 could be rearranged in light of the Combined Hearing in these proceedings. I was informed at that meeting that the assessments cannot be rescheduled. The position communicated to me, which is now also confirmed in my updated ULIP (Section 5A, Non-Rescheduling Policy), is that once an oral assessment date has been confirmed by the University, it cannot be rearranged or rescheduled for any reason, owing to the significant administrative investment and resource commitment involved in arranging specialist oral examiners and dedicated conditions. 9. The University further confirmed that the matter did not fall within the Extensions, Deferrals and Mitigating Circumstances ("EDMC") categories in a manner that would enable rescheduling of the assessment dates themselves. I am informed and believe that the University's position is that if I am unable to attend a confirmed oral assessment, that assessment will be treated as a withdrawal from the course given that due to reasonable adjustments not being in place last term, I missed two assessments…”
(emphasis added)[72]So the evidential position on the impossibility of deferral and the consequences of not attending the oral assessments had been firmed up since the fabricated 20 April Assessment Office email and the JSC letter of 21 April.[73]Mr Lodhia’s 10th witness statement exhibited two documents in support of his witness evidence. The first was the email of 20 April which had been enclosed with the JSC Chambers letter and application notice of 22 April. The second was a doctored version of his ULIP. New Section 5A of this document, to which he had cross referred more than once in the body of the witness statement, stated:
“Section 5A – Oral Assessment Adjustments: Contract Law and Criminal Law (Added 24 April 2026) The following adjustments apply specifically to the Contract Law and Criminal Law module assessments. These assessments have been converted to oral examination format in substitution for any written or on screen examination, to accommodate the student’s cognitive disability.”
[74]A detailed explanation was then provided as to why the contract and criminal law assessments had been converted to oral assessments given Mr Lodhia’s alleged difficulty in reading text on screen, and it was said that this was consistent with the University’s obligations towards him under the disability discrimination legislation. As is apparent, it was not true that either of these assessments had been “converted” to an oral assessment, still less had there been any such conversion by way of a reasonable adjustment for the purposes of the 2010 Equality Act. The methods of assessment for both subjects remained what they had always been.[75]Material was also inserted into the fake ULIP to support Mr Lodhia’s claim in his witness statement that it was impossible to reschedule the oral assessments and that if he did not attend he would be treated as having withdrawn from the course. Again, this evidence was fabricated.[76]Ms Verrell’s evidence reveals that she had met with Mr Lodhia on 22 April, as Mr Lodhia said in his 10th witness statement. However, contrary to his evidence, the purpose of the meeting was not “to explore whether the assessments listed on 6 and 7 May 2026 could be rearranged”:
“The meeting on 22 April 2026 was for the purpose of assisting the Claimant with his technology issues accessing Panopto which is another software platform used by the University of Law. IT services were also in attendance at that meeting on 22 April 2026. I provide at pages 105 a document showing a diary invite for a Teams meeting with IT, the Claimant, and myself to resolve the Panopto issue. Exam Support were also invited because the purpose of the meeting was to solve the Claimant’s Panopto issues. At page 106 is an email to the Claimant from me confirming what was discussed at the meeting on 22 April 2026.”
[77]Ms Verrell does indeed exhibit documentary support for her account of that meeting. She also says, and I accept, that nor is it true that Mr Lodhia would automatically fail the course if he did not attend the assessments. Each student may have a total of two attempts without needing an approved EDMC:
“As set out above, the meeting I had with the Claimant on 22 April 2026 did not discuss the assessments arranged for May 2026 or refer to the Claimant’s litigation. I have certainly not told the Claimant that if he did not attend the assessments he would have to re-start his course or that his circumstances would not fall within an EDMC request.”
[78]I pause to note that, in my view, Mr Lodhia had therefore created and sent false evidence in two tranches. The first tranche was the documents which he sent to the Defendants under cover of his email dated 22 April. The second was his 10th witness statement and exhibits which, on their face, were created on or after 24 April and which firmed up on the consequences of not attending the assessments when, on 23 April, rradar had raised the question whether he had applied to defer. I return to this point below because it tends to undermine the explanation for what happened which he has subsequently provided i.e. that there was a series of unfortunate events in which he did not realise that he had sent the wrong (AI generated) documents to rradar and then to the court.[79]In response to Mr Lodhia’s application, Ms Yates filed her 6th witness statement which was also sent to Mr Lodhia by email at 1:43pm on 29 April 2026. Ms Yates cast doubt on the veracity of what Mr Lodhia had said in his 10th witness statement. She also questioned, at the very least, the completeness of the documents which he had exhibited.[80]Mr Lodhia then submitted an 11th witness statement, which was dated 29 April 2026. This confirmed what he had said in his 10th witness statement about the criminal law oral assessment (i.e. that it had been scheduled for 6 May, when in fact it never had been) but said that he had made contact with the assessor and that he was pleased to confirm that, that day, his assessor had agreed to reschedule the assessment to an alternative date. He said that the conflict which had previously existed in relation to 6 May had therefore been resolved, and he was able to attend court on that day. Mr Lodhia’s 11th witness statement exhibited, for the first time, a true copy of his Assessment Timetable and he said, in effect, that the criminal law assessment had been moved to a different date within the 27 April to 15 May window which was identified in this document. He did not say what that date was. In fact, the assessment had not been moved at all. It was on 12 May as it had been since Mr Lodhia had been notified of this on 20 April.[81]In the same witness statement Mr Lodhia said that the contract law oral assessment remained scheduled for 7 May, which was untrue. Having previously said that his contract law assessment had been converted to an oral one for reasons related to his disability, he now also said that he had omitted to mention, in his 10th statement, that he also had a written exam in the afternoon. He said, again, that he was required to sit the oral assessment as a reasonable adjustment. Again, this was untrue. Mr Lodhia’s position was therefore that he would not be able to attend the hearing on 7 May. He could attend on 6 May, and the preliminary issues as to meaning could be determined on that date, but the issues as to costs should be postponed.[82]Mr Lodhia signed the 10th and 11th witness statements to confirm that he believed the facts stated in them were true. Although this was referred to in each statement as a “Statement of Truth” he takes the point that this was not a statement of truth which complied with [2.2] of CPR Practice Direction 22. I do not consider that this point is material for present purposes but no doubt the Law Officers will consider whether it is for theirs. I note that both statements also say, below the “Statement of Truth”, that they were “Prepared by: JSC Chambers (Joseph Chiffers Barrister at Law Limited)”.[83]On 29 April, Steyn J refused Mr Lodhia’s application as framed when it was made but, in the light of his 11th witness statement, ordered that the hearing take place on 6 May, starting at 10am. She expressly refused Mr Lodhia’s request to postpone the hearing of the issues in relation to costs.[84]As noted above, Steyn J also had concerns about the veracity of Mr Lodhia’s witness evidence about his exam timetable, and about the authenticity and completeness of the documents which he had submitted in support of his account. These concerns are explained in the Reasons for her Order (paragraphs A to I) which she gave including the following, which I set out verbatim because she evidently intended that Ms Verrell would see them, and because Mr Lodhia subsequently deleted them from her Order so that Ms Verrell would not: “A. This is, in effect, the fourth time the Claimant has sought to adjourn this hearing as his stay application would have had the same effect. It follows his initial obstructive approach to listing last year when he provided no dates of availability prior late June 2026. B. In his application (the Claimant’s Third Adjournment Application) and evidence in support, he has stated that on 20 April 2026 the University Assessment Office notified him, for the first time, that he would have a “Criminal Law – Reasonable Adjustments Oral Assessment” on 6 May from 12pm to 2pm and a “Contract Law – Reasonable Adjustments Oral Assessment” on 7 May 2026 from 9am to 12pm. He sought adjournment of the Combined Hearing to a date to be fixed. C. However, in light of the Claimant’s eleventh witness statement it is clear that he is not maintaining that the Combined Hearing cannot go ahead at all. He has stated that today (29 April 2026) his assessor at the University of Law agreed to reschedule his Criminal Law oral assessment to a different date, so he is unavailable to attend the hearing on 6 May 2026. But he maintains that he cannot attend on 7 May due to his Contract Law oral assessment and he seeks to have the costs matter adjourned. ….. G. ……I have some concerns as to the authenticity of the documents exhibited by the Claimant to his tenth and eleventh witness statements, and the truthfulness of his evidence. In order to allay these concerns, I have made the order in paragraph 4 above... H. The Claimant has named Salome Verrell in his tenth witness statement as the University of Law Programme Lead, stating that he attended a meeting with her at which he sought to have the assessments scheduled for 6 and 7 May 2026 rearranged in light of the listing of the Combined Hearing on those dates. In the circumstances, I consider it necessary to seek an independent witness statement from Ms Verrell addressing the matters I have identified, having been provided by the Claimant with this order and his statements.” …..[85]At paragraph I of her Reasons, Steyn J set out the features of the documents exhibited by Mr Lodhia which raised questions about their authenticity.[86]Under [4] of the Order itself Steyn J required that Mr Lodhia file and serve:
“a. A witness statement made by the Claimant: i. exhibiting (i) the original version of the email from the Assessment Office [dated 20 April]….; (ii) all communications between the University of Law and the Claimant, including any general notifications to students, regarding the exam timetable for the academic year 2025-2026; (iii) all communications between the University of Law and the Claimant regarding his Inclusion Plan, including but not limited to any communications regarding oral assessments for Contract Law and Criminal Law; (iv) and any communications between the University of Law and the Claimant in which he notified the University of Law of the hearing listed for 6-7 May 2026, any formal application or informal request by him to have any examination or assessment on those dates re-scheduled, and any response from the University of Law; and ii. confirming that he has exhibited true copies of all the documents in his possession identified in subparagraph (i) above; and iii. confirming that he has provided Salome Verrell with a copy of this Order and his tenth and eleventh witness statements and exhibits thereto. (emphasis added) b. A witness statement from Salome Verrell…: i. Confirming that the Claimant has shown her a copy of this Order, and his tenth and eleventh witness statements and exhibits; and ii. Confirming (or otherwise) that Section 5A of exhibit 1 to the Claimant’s 10th witness statement was added to the Claimant’s Inclusion Plan on 24 April 2026 iii. Confirming (or otherwise) that the Claimant was first notified by the University of Law that he had a “Criminal Law – Reasonable Adjustments Oral Assessment” on 6 May 2026 and a “Contract Law – Reasonable Adjustments Oral Assessment” by the email dated 20 April 2026 and timed at 14:00:45; iv. Confirming (or otherwise) that the Assessment Timetable at exhibit B to the Claimant’s eleventh witness statement (including in particular two entries for “Contract Law”, giving “Submission Date/Oral Assessments Period” of 6 and 7 May 2026) is a true copy of the Assessment Timetable provided by the University of Law to the Claimant; and v. Any other matter the witness considers the Court should be aware of.”
(emphasis added) i. exhibiting (i) the original version of the email from the Assessment Office [dated 20 April]….; (ii) all communications between the University of Law and the Claimant, including any general notifications to students, regarding the exam timetable for the academic year 2025-2026; (iii) all communications between the University of Law and the Claimant regarding his Inclusion Plan, including but not limited to any communications regarding oral assessments for Contract Law and Criminal Law; (iv) and any communications between the University of Law and the Claimant in which he notified the University of Law of the hearing listed for 6-7 May 2026, any formal application or informal request by him to have any examination or assessment on those dates re-scheduled, and any response from the University of Law; and ii. confirming that he has exhibited true copies of all the documents in his possession identified in subparagraph (i) above; and iii. confirming that he has provided Salome Verrell with a copy of this Order and his tenth and eleventh witness statements and exhibits thereto. (emphasis added) i. Confirming that the Claimant has shown her a copy of this Order, and his tenth and eleventh witness statements and exhibits; and ii. Confirming (or otherwise) that Section 5A of exhibit 1 to the Claimant’s 10th witness statement was added to the Claimant’s Inclusion Plan on 24 April 2026 iii. Confirming (or otherwise) that the Claimant was first notified by the University of Law that he had a “Criminal Law – Reasonable Adjustments Oral Assessment” on 6 May 2026 and a “Contract Law – Reasonable Adjustments Oral Assessment” by the email dated 20 April 2026 and timed at 14:00:45; iv. Confirming (or otherwise) that the Assessment Timetable at exhibit B to the Claimant’s eleventh witness statement (including in particular two entries for “Contract Law”, giving “Submission Date/Oral Assessments Period” of 6 and 7 May 2026) is a true copy of the Assessment Timetable provided by the University of Law to the Claimant; and v. Any other matter the witness considers the Court should be aware of.” (emphasis added)[87]In view of the urgency of the matter, the unsealed order was sent to the parties by Steyn J’s clerk at 7:02pm on 29 April. At 8.27pm Mr Lodhia emailed Ms Uglow as follows:
“Dearest Hannah I hope you are very well. We missed you tonight. I know we have our assessment next week on 6th May 2026 Wednesday morning, but I am in court in the morning, and I am wondering if we can move this to the following week? Something has gone wrong with my ULAW calendar, I cannot see any of my assessments at the moment, I will get in touch with IT tomorrow. Let me know if I need to make a formal application. Warmest wishes, Amar”
Amar”[88]Although Mr Lodhia relied on this email as showing that he genuinely believed that the assessment was on 6 May, in the light of the evidence as a whole I accept Mr Price’s submission that his email to Ms Uglow was laying a paper trail because he had realised that his falsification of evidence had been, or was likely to be, discovered. What he said in this email was contrary to his evidence, in his 11th witness statement, that Ms Uglow had “today, Wednesday 29 April 2026, agreed to reschedule my Criminal Law oral assessment” i.e. his evidence was that, by the time of the 8.27pm email, the assessment had already been rescheduled. According to Mr Lodhia’ subsequent witness statements he had genuinely believed, since 22 April at the latest, that the assessment was on 6 May and this was how he came to be instructing an AI tool to create first drafts of the letters, application notices and witness statements on this footing. He had also understood since his meeting with Ms Verrell on 22 April that it was impossible to reschedule the assessments. The timing of his email (a week later), and the casual request to reschedule, also do not sit well with these claims.[89]At 7.55am on 30 April, Mr Lodhia sent a letter to Ms Yates on JSC Chambers headed notepaper offering a drop hands settlement of this claim and Claim No CL-2025-000003. In this letter he also referred to other claims and potential claims including a claim based on statements made by Mr Squires at the TTMC AGM on 29 April 2026 which, Mr Lodhia said, implied that he was a “rat”. The offer stated that it remained open until 4pm on 1 May.[90]Mr Lodhia’s alleged misunderstanding of the date of his criminal law assessment was corrected, at 11:44am on 30 April, by Ms Verrell who told him that the assessment was on 12 May (as he well knew).[91]Ms Verrell’s evidence, which I accept, is that at 12.15pm on 30 April Mr Lodhia then purported to send her copies of his 10th and 11th witness statements and Steyn J’s 29 April Order, as he was required by that Order to do. However, these were not true copies of these documents, despite the fact that he was the subject of an order of the High Court, and so was she. He also sent Ms Verrell a draft witness statement which he had prepared for her.[92]There are very serious concerns about what Mr Lodhia sent to Ms Verrell, which the Law Officers will need to consider.[93]First, the 10th and 11th witness statements were not the same versions as those which had been filed with the court and had been considered by Steyn J and they did not include the exhibits to those statements as she had ordered. i) For example, the version of the 10th witness statement which Mr Lodhia sent to Ms Verrell omitted references to the 20 April email. All references to an oral contract law assessment were also removed as were any suggestions that the format of any assessment had been converted from written to oral. All references to new Section 5A of the ULIP and the accounts of why conversion to oral assessments was required and permitted as a reasonable adjustment were removed. So were his claims that the consequences of not attending the assessment would be that he would have to restart the course. In some places text was added. [8] and [9] (now [7] and [9]) were rewritten and watered down considerably (compare the text at [71], above), so that they said:
“7. On 22 April 2026, I attended a meeting with the University of Law Programme Lead, Salome Verrell. The purpose of that meeting in part to explore whether the assessments could be rearranged in light of the Combined Hearing in these proceedings. I was informed at that meeting that the assessments cannot be rescheduled. The position communicated to me, is that once an assessment date has been confirmed by the University, it cannot be rearranged or rescheduled unless there are mitigating circumstances. 9. As I understand an interim application Court hearing for a civil case does not fall within the Extensions, Deferrals and Mitigating Circumstances (“EDMC”) categories in a manner that would enable rescheduling of the assessment dates themselves.” ii) The version of the 11th witness statement which Mr Lodhia sent to Ms Verrell had also been substantially rewritten. For example, again, all references to there being an oral contract law assessment were taken out. The account of Mr Lodhia being in contact with the assessor and the latter agreeing to move the assessment etc so that he could now attend on 6 May was cut so that an amended paragraph simply said that the assessment was “now actually on 15 May 2026”
. He also cut and rewrote what he had said about the contract law assessments so that the false account about it being converted to an oral assessment by way of reasonable adjustments etc was removed. iii) There were various other amendments to the versions of the 10th and 11th statements but, in short, by editing, cutting and rewriting various paragraphs Mr Lodhia removed or watered down anything which would alert Ms Verrell to the false statements which he had made to rradar in the correspondence, and in his application to the court and the evidence in support of it. She would know, for example, that there had never been an oral contract law assessment, so this evidence was removed. References to the fabricated documents on which he had relied, but which she would be able to check, were also removed and he did not send these documents to her as Steyn J had ordered.[94]Second, the draft witness statement which Mr Lodhia provided to Ms Verrell was not one to which she was prepared to put her name because it was not true. In particular, Mr Lodhia was proposing that she provide a statement which said that there had indeed been a criminal oral assessment scheduled for 6 May and a contract law assessment scheduled for 7 May (he was careful not to say in the draft that this was an oral contract law assessment). She was also being asked to confirm that the criminal law oral assessment which had been scheduled for 6 May now appeared in the University calendar for 12 May, and to say that she was unable to account for the mechanism by which the rescheduling occurred.[95]Third, the version of the Steyn J Order of 29 April which Mr Lodhia provided to Ms Verrell had been converted by him from a pdf into Word and very significantly altered. The alterations included the following: i) References, in the recitals and [4] of the Order, to the contract law assessment being oral had been removed. ii) All references to the 20 April 2026 email from the Assessment Office had been removed. iii) The reference to (fake) section 5A of the ULIP in [4(b)(ii)] of the Order had been removed, and this sub paragraph had been replaced with a made up paragraph. iv) [4(b)(iii)] of the Order had been edited so that it no longer referred to “Reasonable Adjustment Oral Assessment” in relation to the criminal or the contract law assessments. Instead, it referred to a “criminal law oral assessment” and a “contract law assessment”. v) [4(b)(v)] of the Order, which required Ms Verrell to deal with any other matters which she considered the court should be aware of, had been removed. vi) All of the reasons given by Steyn J, explaining why she had made her Order, had been removed.[96]Mr Lodhia told me, and I accept, that hitherto he had had a warm relationship with Ms Verrell, who had been very supportive of him. He also relied on a glowing reference for him which she provided in December 2025, supporting his application to join the Inner Temple. In contrast to some of the claims he has made about his cognitive ability in these proceedings, this reference spoke of his “sound ability to analyse complex information, identify material issues, exercise sound judgment, perceptiveness and good memory”. It referred to him having “the best character” and said that he was “fluent and articulate in his delivery..…persuasive, very confident and knows how to tailor his style to the audience”. Evidently, he had hoped that she would bail him out. He told me that as a result of her experience of his purported compliance with the 29 April Order their relationship had broken down, and this was one of the reasons why he was now leaving the University of Law.[97]At 2.18pm on 30 April, Mr Lodhia then submitted a letter addressed to Steyn J from JSC Chambers (author unidentified) to CE file (“the JSC withdrawal letter”). He emailed it to Steyn J’s clerk at 5.43pm. The JSC letter purported to “write on behalf of the Claimant, Mr Amar Lodhia”. It noted the requirement for him to file and serve further evidence under [4] of the 29 April Order. It stated that Mr Lodhia had been in contact with the University of Law that afternoon and the University was “unable” to provide the statement from Ms Verrell which had been ordered. This was not true, as Ms Verrell’s witness statement has demonstrated. The letter therefore purported to withdraw Mr Lodhia’s 10th witness statement and the exhibits thereto “in order assist the Court and to remove any further distraction from the core issues in this claim”. On this basis, the letter said, the factual basis on which [4] of Steyn J’s Order was made “no longer falls to be addressed”. The Court was therefore invited to note that compliance with [4] was “no longer possible or required”. Of course, it was not for Mr Lodhia or JSC Chambers to make such a decision: it was a matter for the court. This letter was, in my view, part of a damage limitation strategy after Ms Verrell had refused to go along with the draft witness statement which Mr Lodhia had prepared for her.[98]At 3.55pm the University of Law legal services department then sent Mr Lodhia a letter dated 30 April which he sent to the court at 4.15pm. Mr Lodhia made a virtue of taking this step in his submissions to me but I am afraid that it did not persuade me, in the context of the evidence as a whole, that this showed that he had nothing to hide. No doubt he was panicking at this point knowing what the potential consequences of his actions were, and he may well have thought that the University was also likely to write to the court.[99]It appeared from the University’s letter that Mr Lodhia had provided Ms Verrell with “an unsealed word version of an Order”. The letter said that it was unclear whether this was a genuine order and that the University was unaware of the proceedings and did not understand why Ms Verrell was being asked to provide a witness statement. It also appeared that Mr Lodhia had sent Ms Verrell a draft witness statement for her to approve, but the letter said that she had not had any discussion with him about the content of the draft and she wished to make clear that it was not her witness evidence. The letter requested a copy of any sealed order and indicated that the deadline for compliance was too tight.[100]In reply to this letter, Mr Lodhia immediately sent the JSC withdrawal letter to the legal services department of the University saying that he had withdrawn his witness statement and hoped that the matter would be resolved with the court. He apologised for dragging the University into this matter and offered to file the letter “for completeness”.[101]In the light of the University’s letter, on 30 April Steyn J extended the deadlines for compliance with her 29 April Order as follows: the deadline for Mr Lodhia’s witness statement was now 4.30pm on Tuesday 5 May, and the deadline for the witness statement of Ms Verrell was Friday 15 May 2026. Steyn J also caused a copy of her Order of 29 April and Mr Lodhia’s 10th and 11th witness statements and their exhibits to be emailed directly to Ms Verrell and the University given that it appeared that Mr Lodhia had not provided them with these documents as required by the 29 April Order. This was done at 5.37pm on 30 April.[102]Mr Lodhia then emailed legal services at the University again at 5:42pm, saying that he believed that there had been “some confusion as to the versions of the documents filed and provided to you. I have withdrawn the witness statements so there is no need to reply” (emphasis added). This was a continuation of his damage limitation strategy but it is worth noting that he appears, in effect, to have been encouraging the University not to comply with an order of the court. At 6:03pm, Mr Lodhia emailed the University a copy of a notice of discontinuance of the proceedings against the Defendants. His objective in doing this appears to have been to persuade the University that there was no need for it to respond to (i.e. comply with) the Order of Steyn J.[103]At 6.14pm, Mr Lodhia then emailed the Defendants’ solicitors a signed notice of discontinuance. The covering email said that any application for costs would be resisted and it referred to Mr Squires’ comments at the AGM on 29 April as unreasonable conduct which was relevant to costs under CPR Rule 44.2. Mr Lodhia also said that if the Defendants sought their costs of the proceedings he intended to issue a further claim based on Mr Squires’ actions. The email concluded that the relentless nature of the litigation, and in particular Mr Squires’ actions, had had a profound and serious effect on Mr Lodhia’s health such that this was a matter which he may place before the court in the context of claims for injury to feelings and aggravated damages. I note that the email did not suggest that the actions of Mr Squires, or the alleged position in relation to Mr Lodhia’s health, had caused him to decide to discontinue. No explanation for this decision was provided.[104]In his written submissions of 5 May 2026 for the hearing on the following day (see [23] and [24]) Mr Lodhia emphasised that his 10th witness statement had been withdrawn. He said that he did not rely on it and argued that the Defendants’ arguments on this issue were “academic”, and the court’s concerns as reflected in the 29 April Order “are addressed by withdrawal”. However, even at this stage he did not explain why the statement had been withdrawn or what had happened. He took essentially the same position in his 15th witness statement of the same date.[105]At [116] of the 1st Judgment, I noted that the flurry of documents from Mr Lodhia before the 6 May hearing did not include any witness statement from him which purported to comply with Steyn J’s Order of 29 April. When I pointed out to him that he was in breach he accepted that he was but said that he had only realised that “today”. That was, in my view, untrue. He said, for the first time, that he wished make an oral application to set aside the Order on the grounds that the information ordered was “not required”. Ms Verrell “doesn’t have the information that’s being sought and she made that quite clear”. He said that this had also been made quite clear in the 30 April letter from legal services (again, this was not the case). The most important thing “out of all of this kerfuffle with this university timetable” was whether he had an exam on 6 May, what time the exam was and whether the timetable was genuine…maybe also when I became aware that the exam was no longer listed on the 6th”. He also confirmed, when asked, that he was no longer suggesting that the Order was “academic” because the witness statements had been withdrawn.[106]I declined to discharge or vary Steyn J’s Orders. In my view they were and remained justified for the reasons which she gave. Far from subsequent events casting doubt on her reasons, they had increased the court’s level of concern. That judgment has been entirely vindicated in the light of Ms Verrell’s witness statement of 15 May 2026 and the documents which she exhibits, many of which were in Mr Lodhia’s possession but, despite the 29 April Order that he provide them, were seen by the court for the first time when she provided her statement.[107]In the first version of his 17th witness statement, dated 7 May 2026, Mr Lodhia gave his first explanation of what had happened. It is worth bearing in mind that this was his purported response to the 29 April Order and that his statement included a statement of truth. In this statement he apologised for what he said were errors in his 10th and 11th witness statements. His said that he had used AI to assist him in relation to his 10th witness statement. Because of his disability he used AI “as a guide” i.e. “to help with the structure of a document such as headings and the formulation of sentences – not to rely on it for the substance or factual content of any statement filed with the court. I review and prepare the substantive content myself” (emphasis added). On this occasion, the AI draft was saved into the same folder as the correct version of the 10th witness statement and, as a result, the AI version rather than the finalised version had been attached to the 22 April 2026 application notice. This had not been his intention.[108]In relation to the 11th witness statement, Mr Lodhia said that he had used AI in the same way and had built on what he believed to be the final version of his 10th witness statement. Unfortunately, again mistakenly and without realising, he had built on the AI generated draft of that statement. He said, amongst other things, that “at the time of drafting I understood that my criminal law assessment had been rescheduled to 15 May 2026, but the assessor subsequently confirmed the date as 12 May 2026”. This was untrue, as Ms Verrell’s evidence shows. At 8.27pm on 29 April he was claiming to Ms Uglow that he understood that the assessment was on 6 May. He also maintained, in his original 17th witness statement, that the criminal law assessment had originally been scheduled for 6 May but was “now showing on the 12 May 2026”. Again, this does not accord with the evidence.[109]Mr Lodhia said that following Steyn J’s Order of 30 April he had sought legal advice as to the right way to remedy the situation “rather than act precipitously” and, having done so, his 17th witness statement and what he exhibited as the correct versions of the 10th and 11th witness statements were “the product of that advice”.[110]Exhibit 2 to what Mr Lodhia said was the true version of his 10th witness statement was a screenshot of a calendar entry which was evidently intended to back up his claim that he understood that the criminal law oral assessment was on 6 May. However, as Ms Verrell points out, there are oddities about this screenshot, not least that the calendar entry records “Tuesday 5 May No Events”. “Tuesday 6 May 12pm Criminal Law Oral 45min”. In fact, 6 May was a Wednesday.[111]This version of Mr Lodhia’s 17th witness statement did not begin to explain what had happened and, as I have noted, it gave further false evidence and exhibited a false calendar entry. The explanation of how the original versions of the 10th and 11th witness statements came to say what they said was inadequate. I am quite prepared to accept that Mr Lodhia used AI to create documents but what required to be explained is how the AI tool came to be generating documents which painted a false picture, and doctoring others, without any prompting to do so by Mr Lodhia.[112]Nor did the 17th witness statement explain the 22 April 2026 email to rradar with its enclosures including the JSC letter of 21 April, the 20 April Assessment Office email and the contents of the application notice itself. Nor did it explain how the doctored 20 April Admissions Office email and ULIP came to be exhibited to the 10th witness statement. And nor did Mr Lodhia explain his dealings with Ms Verrell in relation to Steyn J’s Order and the doctored versions of the documents which he sent her at 12:15pm on 30 April. He did not exhibit the email correspondence with the University which he had been ordered to produce and which Ms Verrell then produced. Finally, it did not explain how it had come to pass that Mr Lodhia had sent several documents to rradar and then to the court without reading them (given his claim that he had not appreciated that he was sending the “wrong” versions of all of these documents).[113]Mr Lodhia then purported to respond to Ms Verrell’s witness statement in his 19th witness statement, dated 18 May 2026, which was signed with a statement of truth. In this statement he accepted that at the time of his 11th witness statement the criminal law assessment was scheduled for 12 May. He relied on the evidence of Dr Tsakopoulou and what had happened at the AGM on the night of 29 April as explaining his discontinuance of the Claim. He argued that no prejudice had been caused by his 29 April application as the 6 May hearing had gone ahead. He claimed that at the meeting with Ms Verrell on 22 April he had said to her that his criminal law assessment had been showing in his My ULaw application for 6 May 2026. However, he did not contradict her evidence about that meeting, which was directly at odds with what he had said in his 10th witness statement (both the original and the amended versions).[114]Mr Lodhia’s explanation for substantially amending the 29 April Order was that he was confused because the Order did not correspond to the witness statements which he believed he had filed, and that he explained to Ms Verrell “that the version of the Order which I had was an unsealed copy, on the footing that I had it in mind to asked the court to amend the Order under the slip rule”. When the court sent through the correct versions of the witness statements he realised what had happened and he emailed legal services at 5:42pm saying that he believed that there had been “some confusion as to the versions of the documents filed and provided to you”. As noted above, he did send the email but in my view he was attempting to close things down.[115]Mr Lodhia’s explanation for why he sent a set of misleading documents to Ms Verrell does not make sense and I do not believe it. As I have said, in my view the reason why he edited these documents was to maximise his chances that Ms Verrell would not realise that the court had been misled by him and would be willing to sign the statement which he had drafted and which fudged the rescheduling point. This attempt to sweep the matter under the carpet was unsuccessful.[116]In the amended version of Mr Lodhia’s 17th witness statement, which was submitted to CE file on 26 May 2026 (so 11 days after Ms Verrell’s witness statement) Mr Lodhia attempts to explain the calendar entry referred to above (which had 2 Tuesdays in the same week) as follows:
“At the time the AI-assisted draft was prepared, I honestly believed that my Criminal Law assessment was scheduled to take place on 6 May 2026. That honest but mistaken belief was the basis of the instruction (or “prompt”) which I entered into the artificial intelligence tool. It is for that reason that the tool generated, in error, the calendar image and exhibit which depicted a Criminal Law assessment on 6 May 2026.”
[117]He went on to say that his email to Ms Uglow at 8:37pm on 29 April showed that he genuinely believed that the criminal law oral assessment was on 6 May. And he now deleted the claim, in the original 17th witness statement, that “at the time of drafting I understood that my criminal law assessment had been rescheduled to 15 May 2026, but the assessor subsequently confirmed the date as 12 May 2026”. He also amended the statement so that it said that the 6 May assessment had been moved to 12 May. Again, this was not true. Apart from these changes, the 17th witness statement said materially the same as the original and therefore continued to misrepresent the position and to fail to explain significant areas of concern which were raised by Ms Verrell’s evidence. Again, the statement included a signed statement of truth.[118]For completeness, I note that Mr Lodhia made a further witness statement which purported to comply with the 29 April[119]As Mr Lodhia’s evidence did not explain the 22 April documents which he sent to rradar, I asked him about them at the hearing. He said that all of the false evidence and documents were created by AI and were AI hallucinations. He provided a more detailed explanation in his 27th witness statement which was essentially to the same effect i.e. that he had mistakenly sent the wrong documents, AI having generated the false ones without his knowledge and without him realising what had happened. His 27th witness statement includes the detailed prompts which he says he put into the AI tool and exhibits from his output folder, but his explanation requires the court to accept that, having been told on 20 April that his oral criminal law assessment was on 12 May, on the following day he genuinely believed that it was on 6 May. It also requires acceptance that the AI tool generated documents which were false in other respects without any instruction or request from him to do so, that he then mistakenly sent off the wrong versions twice and that he did so without reading them and realising that they were false at any point before Steyn J’s Order.[120]The fact that the documents appear to have been drafted in two tranches and sent on two different occasions also makes Mr Lodhia’s account less plausible. Apart from the inherent weaknesses in his account, that account has to be viewed in the context of the full sequence of events set out above, which includes a number of other steps taken by Mr Lodhia which show that what he says cannot be taken and face value. And that sequence, in turn, requires to be considered in the context of the evidence as a whole, which demonstrates a number of other instances of Mr Lodhia manipulating the evidence. I therefore do not believe the various explanations for his actions which Mr Lodhia has put forward.[121]Finally in terms of the chronology, Mr Lodhia was subject to disciplinary proceedings for gross misconduct by the University of Law. After a hearing on 15 June 2026, he was given a final written warning. The disciplinary panel concluded that there was insufficient evidence that he acted with intent to deceive but that his conduct, which the Panel described as “reckless and careless”, had brought the University into disrepute.[122]Although Mr Lodhia places reliance on this decision as showing that he had not intended to mislead anyone, it is apparent from the Panel’s Outcome Report dated 16 June 2026 that it was focussed on the submission of “inaccurate documents to the High Court and the University” and, in particular, the 10th witness statement. The Panel does not appear to have focussed on the fact that false evidence and documents had also been sent by Mr Lodhia to rradar on 22 April 2026, nor on the 11th witness statement, nor on Mr Lodhia’s explanations in the two versions of his 17th witness statement. Nor was the Panel aware of the wider picture of Mr Lodhia’s conduct which the Court has, some of which I explain in this judgment. Had it been, these matters would no doubt have had an impact on its assessment of his account that there had been a series of unfortunate but unintentional errors on his part. Conclusion[123]In the light of these findings, I have no hesitation in concluding that the third postponement application was totally without merit. In my view this is also an aspect of the case which the Attorney General’s Office should consider. I refer, in particular, to the concerns which I have explained about: multiple false statements verified with a statement of truth, reliance on fabricated documents, the doctoring of an order of the court, and failure to comply with orders of the court. THE MARCH 2025 LETTERS BEFORE CLAIM

Overview

[124]The issue under this heading is whether Mr Lodhia fabricated a series of letters of claim and submitted false certificates of service in order to support an argument that the Defendants should pay his costs, alternatively he should not have to pay theirs, because they had acted unreasonably in the pre action correspondence. For the reasons set out below, I have concluded that he did. Analysis of the evidence[125]I touched on this issue at [54] to [61] of the 1st Judgment. However, to recap, on 11 January 2026 Mr Lodhia applied to amend his Particulars of Claim and for the dismissal of the Defendants’ summary disposal application on the ground that it was “otiose” in the light of the proposed amendments. He also sought his costs of this application on the basis that the Defendants had failed to comply with the Pre-Action Protocol for Media and Communications Claims (“the PAP”) by refusing to provide information which they were required by the PAP to provide.[126]The 11 January application was supported by Mr Lodhia’s 4th witness statement, dated 10 January 2026. In this statement he said that he had sent a letter to rradar “solicitors for the First Defendant” on 6 March 2025 which complied fully with the PAP. This letter indicates on its face that it was sent by email and by post, and it is accepted by the Defendants that it was emailed to rradar and posted to TTMC/Urang.[127]At [6] of his 4th witness statement, Mr Lodhia said:
“On 7 March 2025, I sent a further Letter of Claim directly to TTMC and to Urang…..by first-class post. A copy is exhibited..”
(emphasis added)[128]The exhibit was a single letter headed “BY FIRST-CLASS POST” and the addressees were:
“1) THE DIRECTORS, TWELVE TREES MANAGEMENT COMPANY (BROMLEY BY BOW) LIMITED 2) URANG PROPERTY MANAGEMENT LIMITED”
[129]A single address was given for both of these addressees. This was the address of Urang, which was also TTMC’s registered address. The 7 March letter threatened a claim in defamation and, under the heading “Required Information Under the Protocol” asked for all persons involved in the authorship, editing and publication of the allegedly libellous Newsletter to be identified. Mr Lodhia’s evidence in his 4th statement was that:
“No Defendant responded at all to either Letter of Claim. There was no acknowledgement, no substantive response, and no engagement of any kind with the Protocol.”
(emphasis added)[130]So Mr Lodhia had issued proceedings. He said that as he had no factual confirmation as to which individual Defendants authorised, edited, approved or authored the Newsletter he was forced to plead on the basis of reasonable inferences from the fact of the publication, the corporate roles of the Defendants and the manner of dissemination of the Newsletter. He had also sought further information in July 2025, but had not received it until he read the witness statements which supported the summary disposal application. The Defendants should therefore pay his costs.[131]Before me on 6 May, Mr Lodhia’s position remained that I should order the Defendants to pay his costs of their summary disposal application and his application to amend, as the Defendants’ alleged breaches of the PAP had caused him to incur unnecessary costs. In the alternative, he submitted that the costs should be in the case. He also argued that, for the same reasons, I should not order him to pay the Defendants’ costs of his discontinuing the proceedings. I rejected these arguments for reasons which I explained, and I did so on the assumption, although noting that this was in issue, that the 7 March letter had been sent. In short, I concluded that it was Mr Lodhia’s conduct of the correspondence and the claim which had been unreasonable.[132]Ms Yates’ 5th witness statement, dated 21 April 2026, was written in the context of Mr Lodhia’s 4 April application for a stay where, as noted at [45] above, he deployed the same material and argument in his 9th witness statement as part of his contention that there was no realistic prospect of the Defendants recovering their costs. She noted that although the 6 March letter (which was addressed to TTMC) had been emailed to rradar and received, there was no record of the 7 March letter having been received by rradar. She had also checked with the TTMC Defendants whether they had any record of the 7 March letter having been received, and they did not. She also said that she had been told by Mr Squires that if letters were sent to Urang’s office which were addressed to TTMC, Urang would scan and email them to the directors of TTMC. Urang had also confirmed that this was its process. The only letter from Mr Lodhia which Urang could find in the relevant time frame was the 6 March letter to TTMC, which was received by post on 12 March and scanned to TTMC on the same day.[133]Even at the stage of Mr Lodhia’s 4th witness statement it was not clear why, having emailed and posted the 6 March letter before claim, he would decide to send a further PAP letter the next day, why by post only and why not to rradar as well (as with the 6 March letter). It was also odd that, although Mr Lodhia had a habit of chasing correspondence to which he had not had a response, he had not chased for a response to the 7 March letter.[134]However, in addition to this, Mr Lodhia had said in his 4th witness statement that the 7 March letter was sent to TTMC and Urang and at a single address and had indicated that a total of 2 letters were sent: this one and the letter to rradar on 6 March. He also referred to only one letter of 7 March in his 9th witness statement (see [6] of that statement). He did not suggest in either statement that letters of claim were sent to the Third to Fifth Defendants separately as well, nor that there was a second letter of claim to rradar. Nor did he suggest that any letter other than the first letter to rradar/TTMC had been sent on 6 March.[135]But at the hearing on 6 May Mr Price showed me, in Mr Lodhia’s bundle served the day before the hearing, individual letters of claim to each of the Third to Fifth Defendants at their personal addresses, and a letter to rradar at its physical address. These letters were dated 6 March 2025 but headed “Second Letter – Defamation Claim”. Like the 7 March letter, under the heading “Required Information Under the Protocol” they all asked, amongst other things, for all persons involved in the authorship, editing and publication of the Newsletter to be identified. In the case of the letters to the Third to Fifth Defendants, another oddity was that they were being sent a second letter of claim when Mr Lodhia does not suggest that they had been sent a first one. Moreover, it was odd that, having written and posted a letter to TTMC and Urang on 6 March, on the same day Mr Lodhia would also post (but not email) a second letter to rradar who acted for TTMC.[136]Even more concerning was that fact that, in the same bundle, there was also a series of certificates of service of the second 6 March letters to the First to Third Defendants and rradar. These certified that each of the letters was sent by first class post on 6 March and were deemed to be served on 8 March. The disputed letters were also filed with the certificates of service. This was the first time in the litigation that the individual letters had been produced in evidence or referred to by Mr Lodhia, still less had they been chased by him in his usual fashion. Mr Price also pointed out that the certificates all purported to have been signed by Mr Lodhia on 7 March 2025. However, they bear the case number for these proceedings which were not issued until more than 2 months later. They therefore could not have been completed until after 15 May 2025.[137]On the face of it, it appeared that Mr Lodhia had created the new 6 March letters and the certificates of service to support an argument that the Defendants had failed to provide him with crucial information in the pre action protocol correspondence and that this was relevant to the issue of costs. When I asked him about these documents at the 6 May hearing, Mr Lodhia denied this. He said that he was sure that I was used to “cases where you tie up admin at the end of litigation”. The certificates had been filed three or 4 weeks earlier (which in fact was very much before the end of the litigation – the combined hearing was coming up) and the date on the certificates was wrong. He said that he believed that the right approach when signing them was to put the date on which they were served rather than the date on which they were signed.[138]I do not believe this explanation for the dating of his signatures. Mr Lodhia signed under the heading “I believe the facts stated in this certificate are true” and he put the date into the box below his signature. By doing so, he was representing in a formal court document that he had signed on 7 March 2025, as he well knew. Moreover, the certificates said that the letters were sent on 6 March and deemed served 8 March i.e. Mr Lodhia did not put in the date of service below his signature.[139]At the 6 May hearing, Mr Lodhia also took me to a receipt, various copies of which were in his bundle for the 6 May hearing. This was dated 6 March 2025, and it related to a payment of £12.90 to a post office in Romford. What had been paid for was and is not apparent on the face of the receipt. However, Mr Lodhia told me that there were four letters which were sent, and that the cost of a first-class large letter was £3.25. He said that if you multiplied this by 4 you got £12.60, and he had also bought a bit of chewing gum. He would provide a witness statement to confirm this, and he would explain in his statement why he sent the letters by post but not by email. In fact the total for the letters would have been £13, so this account literally did not add up.[140]In the light of these concerns, on 18 May I ordered that Mr Lodhia provide a witness statement which explained when the disputed letters were drafted and the method by which they were sent, which addressed the issues in relation to the certificates of service which he had filed and which exhibited any proof of postage. He was also ordered to send all original digital files of the disputed letters and certificates including any formats, versions and drafts to email addresses in the form of individual attachments preserving the metadata associated with those files.[141]In his 20th witness statement, dated 29 May 2026, which was verified by a statement of truth, Mr Lodhia stated that the disputed letters were correctly dated and were sent by first class post. There was one electronic version of each of the disputed 6 and 7 March letters. What he had done was alter the addressee/address on the electronic version and print the letter up, then alter the addressee/address again and print it up etc before posting the hard copies. This accounted for the fact that he was not able to provide electronic versions of all of the letters sent to the Defendants. Nor had he maintained the metadata for the electronic versions, which showed a “last modified” date of 29 May 2026 because he had accessed the document for the purposes of preparing his statement. He had prepared the certificates of service on or before 18/19 April 2026 whilst preparing the bundle for the combined hearing in May (at which one of the issues was the costs of his conceding the Defendants’ application for summary disposal of part of the case). These had been filed, with the letters, at that point. He enclosed the Post Office receipt for £12.90 but provided no further explanation of this.[142]In her 8th witness statement, Ms Yates points out that the logic of Mr Lodhia’s explanation of why he only had one electronic version of the 6 March letters would mean that on 18/19 April 2026 he was only able to file the last letter which he had posted. According to him the others had been amended but not saved. He had not explained how, then, he was able to file and include in his bundle for the combined hearing, copies of each of the 4 letters to the four different addressees, attached to the 4 certificates of service dated 7 March 2025. Moreover, a Google search revealed that the cost of a first-class stamp in 2025 was in fact £1.70. So even if all 5 letters had been sent by first class post the costs would have been £8.50, not £12.90.[143]Mr Lodhia’s 24th witness statement, dated 23 June 2026 and verified with a statement of truth, also touches on this topic in purported compliance with my Order of 18 May. In it, he reiterates that the certificates of service were part of a tidying up exercise which he had conducted on 18/19 April 2026. He says “I am not aware that a Certificate of Service could not be backdated to the time when the service actually occurred.” Again, I do not accept this explanation.[144]In his 26th witness statement, dated 3 July 2026 and verified by a statement of truth, Mr Lodhia now gave a different explanation for the Post Office receipt, and one which I do not believe either. He said that the payment was for 4 letters but he said that he had sent them in A4 envelopes for which, he now said, the cost of postage was £3.05, and not £1.70 as Ms Yates had said. He did not explain why he sent the letters in A4 envelopes rather than folding them, as might be expected, so as to be able to post them more cheaply. Nor did he explain why he told the hearing on 6 May that the figure was £3.25. He sought to prove his £3.05 figure by reference to a Post Office document which clearly sets out a series of (increased) prices which took effect from 7 April 2025 and therefore does not establish the price when the letters were allegedly posted, a month earlier, at the beginning of March. He said that the total cost was £12.20 and that there was “a small confectionary purchase made at the same time, which accounts for the balance”. His mother had given him the stamp for the 7 March letter as he was staying with his parents in Hornchurch at the time.[145]It is notable that in his 26th witness statement Mr Lodhia relied on what Ms Yates had said on this topic as being an example of a consistent pattern of professional misconduct on her part which amounted to an abuse of the process of the court for which she should be held accountable under the Hamid jurisdiction. It was nothing of the sort. In their skeleton argument for the July hearing counsel for the TTMC Defendants pointed out the discrepancy between what Mr Lodhia said at the hearing on 6 May and what he said in his 26th witness statement as to the price of a first class stamp. They said, correctly, that he had not explained this discrepancy. At the hearing Mr Lodhia persisted in suggesting that this point was made in bad faith. I am afraid that, in truth, this was part of a pattern of him adopting an “attack is the best form of defence” strategy and seeking to distract from the reality of his own conduct. Conclusion[146]In my view this is also an aspect of the case which the Attorney General’s Office should consider. I refer, in particular, to the concerns which I have explained about: false statements verified with a statement of truth, reliance on fabricated documents, the false certificates of service (another important formal court document) and Mr Lodhia’s purported compliance with my Order of 18 May. THE BEGBIES TRAYNOR LETTERS

Analysis of the evidence

[147]I referred to this issue at [17]-[27] of the 1st Judgment. It arose because one of Mr Lodhia’s preliminary points at the 6 May hearing was that the hearing should not go ahead because his trustees in bankruptcy, Begbies Traynor, had not been served.[148]It was apparent from the correspondence that, throughout the proceedings, Mr Lodhia had been taking the position that he was not personally liable for any adverse costs order and that such liability would attach to the estate in bankruptcy. He therefore had no concerns about proceeding with the Claim and this appears to have been part of the reason why he felt able to adopt the high-handed approach which he took. He had also asserted this position vigorously in without prejudice negotiations as a reason why the Defendants should settle with him. His written submissions of 5 May 2026 addressed the authorities relied on by the Defendants and submitted that these supported his contention that the malicious falsehood claim was a chose in action which vested in the trustee in bankruptcy, and that the neutral position of Begbies Traynor meant that they would comply with an adverse costs order against the estate.[149]Mr Lodia’s argument was significantly undermined by an email which was received from Begbies Traynor on the morning of the hearing, to which I refer below. However, at the hearing he also said that the Trustees “could not have their cake and eat it”. They could not consent to him bringing the Claim on the basis that they were entitled to the fruits of the litigation if it was successful, but would not be subject to any adverse costs order if it was unsuccessful. If a costs order were made against him they should therefore also be liable. He thought that they would therefore want the opportunity to respond to the Defendants’ applications for costs and they should therefore have been served.[150]In the 1st Judgment, I rejected Mr Lodhia’s arguments on the basis that they were wrong in law and pointed out that, in any event, the Trustees had been aware of the proceedings for some time and had not expressed any wish to participate or make representations or otherwise be involved. Their view, which I shared, was that Mr Lodhia was liable in respect of any order for costs against him and they were not. Moreover, if Mr Lodhia thought that they should be before the court it had been and was open to him to take steps to bring this about.[151]For the purposes of this issue, there were 4 letters on Begbies Traynor headed notepaper before the court on 6 May: i) The first was dated 30 April 2025 (i.e. during the bankruptcy) and it said that “This letter confirms that the Joint Trustees in bankruptcy of Amar Lodhia have no objection to Mr Lodhia acting in the Kings Bench Division (KBD) in relation to the matter of claim number KB-2025-001785”. The letter specified that any award in these proceedings in Mr Lodhia’s favour was payable to the estate in bankruptcy but any adverse award in respect of costs would not be a liability of the estate and nor would it be borne by the Trustees. A striking feature of this letter was that the heading included the case number for the present Claim despite the fact that proceedings had not been issued until a little over 2 weeks later, on 15 May 2025. At the 6 May hearing the Defendants therefore questioned whether the letter could be genuine. In his written submissions dated 5 May 2026, Mr Lodhia had said, at [12], that “The trustees have post-dated (sic) the letter to confirm that the permission to issue these proceedings was sought before the proceedings were issued. That practice is not misleading or uncommon. There is no inconsistency…..”. As will be seen below, that was not true. ii) Second, there was a Begbies Traynor letter dated 29 November 2025 which purported to supersede the letter of 30 April and said that any award in Mr Lodhia’s favour before he was discharged was payable to the estate in bankruptcy. “Any adverse award regarding proceedings issued after discharge of Mr Lodhia, costs will not be borne by the bankrupt estate or trustees. Therefore, any adverse costs orders arising for (sic) interim applications and/or in proceedings that were issued before Mr Lodhia’s discharge would fall into the estate in bankruptcy…”. Apart from the odd drafting, this was a non sequitur. However, the important point is that the 29 November letter was evidently intended to strengthen Mr Lodhia’s argument that he was not exposed in the event of any adverse costs award. But, as will be seen below, it did not truly represent the position of the Trustees. iii) Third, there was a version of a letter dated 11 December 2025 (“the first 11 December letter”) which, at the hearing, Mr Lodhia said he had filed mistakenly and had withdrawn shortly afterwards. The nature of the mistake was not explained. This letter was to similar effect (though in different terms) to the letter of 29 November 2025 and it referred to “the detailed judgment of Master Dagnall in QB-2022-000089 at a hearing on 13 August 2025” as supporting his position that adverse costs orders in relation to applications and claims issued during the bankruptcy “would become contingent liabilities and will vest in the estate in bankruptcy”. Again, the drafting was odd. It also appeared that Mr Lodhia may have had a hand in it, and that he was bolstering his argument that he was not exposed in costs. Again, this this did not truly represent the position of the Trustees. iv) Fourth, there was a second letter dated 11 December 2025 which adopted the same position as the 30 April 2025 letter (i.e. that neither the estate nor the Trustees would pay any adverse order in costs and, by implication, Mr Lodhia therefore would). This version was emailed to the parties by Ms Kerri Cramphorn of Begbies Traynor at 7:48am on 6 May, so very shortly before the hearing that day. Her covering email, which also contradicted Mr Lodhia’s position in his argument that the Trustees required to be served before the hearing could proceed, stated:
“…As set out in our letter dated 11th December 2025, the Trustee authorised the debtor to proceed with the claim on the basis that: 1. Any settlement and/or award of funds vests in and is payable to the estate in bankruptcy. 2. Any adverse award regarding costs will not be borne by the bankrupt estate or Trustees. It is noted that there are 2 versions of the letter, the second incorporating amendments by the debtor which he submitted to the Trustees for approval, which were subsequently not authorised by the Trustees….(emphasis added) It is the Trustee’s intention to remain neutral in these proceedings.... We have not formed a view regarding the costs Orders which could potentially be made against the debtor, whether these would be provable in the bankruptcy and do not have funds to seek legal advice on this in the circumstances of the case at this time.”
[152]I note that in his 15th witness statement, dated 5 May 2026 (so on the eve of the 6 May hearing) and verified with a statement of truth, Mr Lodhia had claimed that he had spoken to Ms Cramphorn that day. He said that she had confirmed that the Trustees were neutral as to the costs position and would comply with any order of the court; and that “Permission was sought by the Claimant to bring these proceedings on 30 April and was granted by the joint trustees at that time.”. She would confirm this to the court later that evening. As is apparent, she did contact the court but she did not confirm what he said she would confirm. The evidence which she has since provided to the court also shows that there was no grant of permission on 30 April as he alleged, and it was not true that the Trustees were neutral on the question of costs: their clear position, from start to finish, was that neither they nor the estate in bankruptcy would be liable for any adverse costs order in the proceedings.[153]In the 1st Judgment I also noted that in his submissions Mr Lodhia did not rely on the “detailed judgment” of Master Dagnall to which the first 11 December Begbies Traynor letter referred. This was surprising given that he had relied on this “judgment” in his correspondence with the Defendants’ solicitors as establishing that he was immune from any order for costs. He had been asked by rradar for a copy, as it could not be found on the internet, but had refused to provide it. When I asked him, in the context of the question of further directions, whether he would be willing for me to direct that he provide it he said that it was not a judgment, it was a minute or note of the hearing before the Master on 13 August 2025. He was, however, prepared to provide a copy.[154]At 5:09pm on 7 May 2026 (again, after the hearing) Mr Lodhia then sent through Master Dagnall’s Order, dated 2 October 2025, in three other (apparently unrelated) cases in which Mr Lodhia was a claimant (QB-2022-000089, 001776 & 001965). It appeared from this Order that his claims had been struck out for failure to comply with an Unless Order dated 27 June 2023. Mr Lodhia also enclosed a 2 page minute of the hearing on 2 October 2025 (not 13 August 2025) which he had made.[155]In the 1st Judgment I noted that the fact that there was no actual Master Dagnall judgment came as something of a surprise given that this was how it was described in the correspondence, given the terms of the first 11 December letter and given, for example, that when, on 15 December 2025, rradar wrote to Ms Cramphorn asking for a copy of the judgment, Mr Lodhia told them that he had asked her not to reply:
“The judgment can be obtained from the High Court KBD which you are clearly aware of.”
(emphasis added). He had been asked again for a copy of the judgment and he had again said that such requests should be directed to the High Court:
“Continued attempts to extract this from us unnecessarily increase both my firm’s costs and my own. We will not be responding to further correspondence on this issue”
. The 6 May hearing appeared to have been the first time that he admitted that there was in fact no judgment which Begbies Traynor could have seen for the purposes of the first 11 December letter.[156]It was against this background that, on 18 May, I ordered that Ms Cramphorn, or alternatively an individual at Begbies Traynor with oversight of Mr Lodhia’s matter with them, make a witness statement which clarified the position and exhibited, amongst other things, true copies of all written communications (in emails or otherwise) between the Mr Lodhia and Begbies Traynor regarding this claim, and the letters referred to above. I also ordered that the statement provide “any other information, and any other documents, of which the writer considered the court should be aware in relation to this matter given the Court’s wish to understand the circumstances in which the above-mentioned letters came to be created and submitted to the Court and whether they are genuine.”. Ms Cramphorn’s witness statement should be read in this light and I accept that she has fully complied with my Order.[157]Ms Cramphorn helpfully provided a witness statement with exhibits, which is dated 9 June 2026. She explains that she is the Case Manager and her colleague, Mr David Robertson, is the Case Administrator. Together they have the day to day conduct of the bankruptcy estate, which is overseen by Mr Pedhiou.[158]Ms Cramphorn explains the history in relation to each of the four Begbies Traynor letters by reference to the documents which she exhibits (a number of which, including the key ones, Mr Lodhia did not exhibit to his 15th or any other witness statement before they were disclosed by her, although they were in his possession). In the light of her evidence, the following key points are now clear.[159]First: i) A version of the 30 April 2025 letter had been provided by Begbies Traynor at Mr Lodhia’s request in August 2024 for the purpose of proceedings in the First Tier Tribunal. There was a further version provided at his request in January 2025 for the purposes of “unjust enrichment proceedings” in the Commercial Court (case no CL 2025-000003). ii) In their letter dated 13 June 2025 and subsequently, rradar argued that Mr Lodhia lacked standing to bring his claim in malicious falsehood unless and until the cause of action had been assigned to him by his trustees in bankruptcy. iii) On 27 June 2025, Mr Lodhia therefore emailed to Mr Robertson (cc Mr Pedhiou, Mr Andy Gray and Mr Cramphorn) a version of the January 2025 letter which he had now dated 30 April 2025 and amended so that it included (twice) the case number of the present proceedings, rather than that of the Commercial Court claim. His message to Mr Robertson included the following:
“I was wondering if it was ok to send this letter in relation to this matter? Just FYI, the court has transferred the Unjust Enrichment clai (sic) to a different court.” iv) (In fact there was such a claim, and it had been transferred to the County Court). v) On 2 July 2025, Mr Roberton replied (cc Mr Gray and Ms Cramphorn): “Providing this is the same case (just transferred to a different Court, the trustees have no objection to our original consent letter being placed on the file.” vi) In other words, they were authorising the use of the January 2025 letter, given their understanding that this related to the same case, rather than the 30 April letter. vii) Mr Lodhia immediately sent a copy of the 30 April letter to Ms Yates stating that it confirmed “that the Trustees had no objection to me acting in claim KB-2025-001785”
(emphasis added). In his characteristically high-handed style, he told her that her point was “without merit” and said that it was “disingenuous” for her to suggest that the point was other than academic “when the trustees expressly authorised the conduct of the claim prior to discharge”. This was untrue: he was discharged on 10 June 2025. He then threatened her with an application for wasted costs if her client persisted in pursuing this argument, on the basis that it was “wholly misconceived and an abuse of process”.[160]Leaving aside Mr Lodhia’s tone, which aggravates what he did, I accept Mr Price’s submission that what follows from this is that: i) Mr Lodhia’s repeated statements that he was authorised by the Trustees to conduct these proceedings were untrue, as were his statements that he had that authorisation before he had brought the Claim. ii) He had also misled the Trustees in order to get permission to use (more accurately, misuse) the letter. Even if they were authorising the use of the 30 April letter (which I do not think they were) they understood that it related to the unjust enrichment proceedings, which they had authorised in January 2025, rather than the present case.[161]Second: i) By email dated 29 November, Mr Lodhia sought Ms Cramphorn and Mr Robertsons’ approval for the 29 November letter, which he said he had “updated”. Mr Gray was cc’d. As noted above, in fact the letter sought to improve Mr Lodhia’s position in relation to any adverse order for costs against him and did not reflect the Trustees’ position. This letter was not approved by Begbies Traynor, apparently owing to pressure of work. ii) Mr Lodhia nevertheless deployed the 29 November letter in without prejudice email correspondence on 20 April 2026. He both sent the letter and quoted, in full, the paragraph which he had composed and inserted into the letter which said that he was not exposed to adverse costs orders. His email also insisted that the 29 November letter was “strictly confidential” and could not be shared without his consent or put before the court, save as to costs. 5 hours later, the email was then recalled and the first 11 December 2025 letter was sent: see, further, below.[162]Third: i) At 10:51am on 11 December 2025, Mr Lodhia emailed the first version of the 11 December 2025 letter to Ms Cramphorn and Mr Robertson (cc Mr Gray) seeking approval and stating that he needed to file it at 4pm that day. ii) He then emailed this letter to rradar at 12.19pm, specifically drawing attention to its contents including the reference to Master Dagnall’s “judgment” which Mr Lodhia had inserted. iii) At 3.19pm Begbies Traynor sent him the (second) version of the 11 December 2025 letter, which they said they were willing to send but which, though they did not appreciate this, did not suit Mr Lodhia’s purposes. Mr Robertson’s email made clear that the first 11 December letter was not authorised and said in bold “UNDER NO CIRCUMSTANCES should communications from the trustees be altered or amended”. iv) Mr Lodhia then recalled his filing of the first 11 December letter at 3.31pm. However, he did not send rradar the correct version of the 11 December letter with which he had been provided but which did not support his position. Nor did he explain what had happened which had led him to recall the first version. Indeed, he continued to correspond with rradar on the basis of the first version. v) On 20 April 2026, shortly after he had recalled the 29 November letter, Mr Lodhia deployed the first 11 December letter in the context of the without prejudice correspondence and with the same insistence that the letter was strictly confidential and could not be shared without consent. vi) The true version of the 11 December 2025 letter did not emerge until Ms Cramphorn emailed it to the court early on the morning of 6 May.[163]In his 21st witness statement, dated 16 June 2026, Mr Lodhia says that Ms Cramphorn’s evidence is “materially incomplete” and gives this account:
“My principal point of contact at Begbies Traynor throughout the relevant period was Mr Andy Gray, not Ms Cramphorn or Mr Robertson. Mr Gray himself telephoned me to check what claims were being pursued, and in that call – before any of the correspondence with Mr Robertson on which Ms Cramphorn relies – I expressly confirmed to Mr Gray that claim KB-2025-001785 was a new claim for malicious falsehood and defamation. In any event, I required the trustees' permission before the claim could be issued, and I had obtained that permission. The suggestion that the trustees did not know this was a new claim cannot be reconciled with their own position before the Court, namely that they gave permission for these proceedings to be brought: that permission was necessarily given, and the trustees were necessarily aware of the claim, before it was issued. As to the inclusion of the claim number in the correspondence – a point raised by Mr Price KC for the TTMC Defendants at the hearing – a claim number can only be allocated once a claim has been issued. Its presence on the letter therefore shows that the claim had already been issued, and confirms that any reference in my covering message to Mr Robertson to a "transfer" of the earlier unjust enrichment claim was an inadvertent error of description, not an attempt to mislead. Mr Gray has since left Begbies Traynor.”
[164]I note that: i) Although Mr Gray was cc’d on some of the key emails, all of the evidence from Begbies Traynor shows that Mr Lodhia’s main points of contact were Mr Robertson and Ms Cramphorn. ii) There is no date for the alleged conversation with Mr Gray given in this account, and nor are there any notes of the conversation. At the July hearing Mr Lodhia showed me a phone record which, he said, showed a 20 minute call with Mr Gray. Assuming for the sake of argument that this was a conversation with Mr Gray the call took place on 25 March 2025. iii) Whatever Mr Lodhia and Mr Gray may or not have discussed on 25 March, the email exchange between Mr Lodhia and Mr Robertson on 27 June and 2 July (with Mr Gray cc’d) shows the timing of the request for permission to rely on the 30 April letter and what Mr Robertson permitted and on what understanding. Mr Lodhia’s claim that the Trustees knew that this was a new claim and had given permission before it was issued cannot stand with this exchange either. iv) The point which Mr Lodhia makes about the case number turns reality on its head and, bluntly, is nonsense. The real point is that the presence of the case number on the letter showed that it could not have been written on 30 April 2025 and Ms Cramphorn’s evidence confirms that it wasn’t. Mr Lodhia had dated the letter so that he could present it to rradar as showing that he had prior authorisation to bring the Claim, when he did not.

Conclusion

[165]I am therefore satisfied that Mr Lodhia’s argument that the hearing on 6 May 2026 should not go ahead because the Trustees had not been served was totally without merit and based on claims about pre-authorisation of the proceedings, and the position of the Trustees in relation to costs, which were untrue. This was in effect an “application” to postpone the hearing for the purposed of CPR Practice Direction 3C, governing the making of civil restraint orders. But, even if it was not, I consider that I am entitled to take it into account for the purposes of determining whether his behaviour has been “persistent” and in exercising my discretion as to whether such an order should be made.[166]In my view this is also an aspect of the case which the Attorney General’s Office should consider. I refer, in particular, to the concerns which I have explained about false statements verified with a statement of truth and the presentation of documents to the court as representing the position of the Trustees, when they did not. THE 5 MAY STATEMENT OF COSTS

Analysis of the evidence

[167]As noted above, in anticipation of the 6 May hearing Mr Lodhia submitted a N260 Statement of Costs dated 5 May 2026, in which he signed the following declaration:
“The costs stated above do not exceed the costs which the Claimant is liable to pay in respect of the work which the statement covers. Counsel’s fees and other expenses have been incurred in the amounts stated above and will be paid to the persons stated.”
[168]The 5 May statement of costs claimed £70,302.50 plus VAT (c£82,839.40) which included a figure of £10,000 for Mr Chiffers’ fees for “advice/conference/documents”. On the basis of Mr Chiffers’ stated hourly rate of £250, this was the equivalent of 40 hours’ work. This figure appeared implausible given that Mr Chiffers did not appear to have done this amount of work on the case. There were some short written submissions on the file signed “Direct Access Counsel” (though Mr Chiffers name was not used and his evidence is that he did not write these) and there was the 22 April 2026 application notice (which he denies signing), but he had not responded to correspondence and he had not appeared at any hearing. As I noted at [120] of the 1st Judgment, Mr Lodhia also told me that he had paid Mr Chiffers this sum.[169]I also doubted that Mr Lodhia was liable to pay the balance of c£60,000, as he had declared, given that the (at least 375 hours) work which he said had been carried out appeared to have been carried out by him. And, at [120], I noted that the £10,000 figure stood in contrast to the figure of £2,750 (11 hours’ work) in Mr Lodhia’s statement of costs sent to rradar on 8 April 2026. The total figure for costs at that stage was also £29,549, in contrast to the figure of £70,302 in the 5 May statement.[170]When I asked Mr Lodhia about the 5 May statement of costs at the 6 May hearing he said that he had spoken to Mr Chiffers that morning who would be happy to provide evidence to support it. Accordingly, on 18 May I ordered that Mr Chiffers provide a witness statement:
“11.1 explaining the terms on which the Claimant is engaged by JSC Chambers and the Claimant’s role; 11.2 explaining how his supervisory arrangement with the Claimant operates in practice; and 11.3.1. the extent and nature of his supervision of the Claimant in connection with these proceedings and when this began; 11.3.2. the date on which he was instructed by the Claimant; 11.3.3. the work which he has carried out in relation to these proceedings; 11.3.4. whether it is the case that the Claimant is liable to pay fees to JSC Chambers or Mr Chiffers as stated in his Statement of Costs of 5 May 2026; 11.3.5. particulars of the payments which the Claimant has made to Mr Chiffers in respect of his fees. 11.4. exhibiting: 11.4.1 any invoices in respect of services rendered by Mr Chiffers to the Claimant and any receipts or other evidence confirming payment of the same; and 11.4.2 any agreement between Mr Chiffers and the Claimant regarding Mr Chiffers’ supervision of the Claimant in relation to this claim. 11.5. again subject to his professional obligations, providing any other information or documents of which he considers the Court should be aware having regard to the concerns expressed in the 29 April Order of Steyn J and the judgment of the court dated 18 May 2026.”
[171]As noted above, it has required 5 witness statements (six counting his amended 2nd witness statement) to arrive at a clearer answer from Mr Chiffers and I deal with his position below in relation to the question of a Hamid referral. But the following points emerge from Mr Chiffers’ evidence and they stand in stark contrast to what Mr Lodhia has declared in formal court documents, said in witness statements verified by a statement of truth and told the Court and the Defendants: i) Mr Lodhia would not be liable to pay JSC Chambers for the time which he spent working on his own case “and I am unable to identify an agreement providing otherwise” ([18] Chiffers 2). ii) There is no retainer agreement with Mr Lodhia in place in respect of any work which Mr Chiffers has done on this case ([12] Chiffers 5). iii) Mr Chiffers met with Mr Lodhia about the case on 22 December 2025 ([9] Chiffers 1). However, contrary to Mr Lodhia’s claim in his 4 April statement of costs, he did not spend 3 hours discussing the case with Mr Lodhia as would be indicated by the sum of £750 claimed. ([16(b)] Amended Chiffers 2). iv) In contrast to Mr Lodhia’s account for the purposes of the second postponement application (see [41] and [42], above), Mr Chiffers says at [21] of his 5th witness statement that there was “an element of preliminary preparation for trial” but he emphasises that it was “preliminary” and not “trial prep” in the conventional sense. v) Mr Chiffers does not recall what the figure of £2,750 for his work in Mr Lodhia’s 8 April statement of costs refers to. He did not invoice Mr Lodhia for this figure and does not know how that sum was calculated ([19] Chiffers 5). (In his 27th witness statement, Mr Lodhia says that this figure was for a 3 hour conference on 22 December 2025 and 8 hours travel (11 x £250) but this does not fit with Mr Chiffers’ evidence e.g. that the conference did not last 3 hours and that he was in London on other matters. Mr Chiffers also says that travel by train to and from London had taken “circa 4 hours” although I will allow for the possibility that he may have meant “each way”: see [16(b)] Chiffers 2 (amended)). vi) Mr Chiffers cannot recall or identify any particular agreement for JSC Chambers to charge Mr Lodhia £10,000 and the number of hours work which he did on the case was very significantly lower than this figure would suggest ([18(c) Chiffers 2 (amended)). vii) In his 4th witness statement, Mr Chiffers says that the work which he has carried out on this case includes: “(a) Discussing trial strategy with the Claimant and the merits of the case. (b) Advising the Claimant on a proposed amended Particulars of Claim. (c) Advising the Claimant on the meaning of the allegedly defamatory statements. (d) Advising the Claimant on the prospects of a partial strike out Application made by the Defendants. (e) Carrying out trial preparation, (even though my attendance had not been confirmed, I appreciated the amount of work involved and wanted to ensure I would be adequately prepared if I did attend as the Claimant’s counsel). (f) Advice on the principal of costs following discontinuance.” viii) At [11] of his 4th witness statement he says: “An estimate of circa 15 hours would be reasonable for the above work; it is difficult to provide an estimate in the current circumstances and to avoid being unconsciously influenced by the circumstances.” ix) Mr Chiffers goes on to say that he is prevented by litigation privilege from giving a more detailed description of the work which he has carried out. Mr Jones confirmed to me that he was not pursuing any such argument, although I said in advance of the hearing that I would need assistance on why litigation privilege prevented Mr Chiffers from doing so. It is clear to me that Mr Chiffers does not have any actual record of his hours worked on this case or of what he did and has therefore had to give an estimate. This, in my view, reflects that fact that this was an informal arrangement. He himself effectively concedes as much. x) In his 5th witness statement Mr Chiffers says that the work which he did on this case was work for which he expected to be paid - “It was chargeable work payable by Mr Lodia” – but in practice he would not “now” take steps to require payment, and would not have demanded payment in cash for his services. Rather, his practice in the past had been for Mr Lodhia to “work off the cost by working in the JSC practice” ([21] Chiffers 5) i.e. to do some work for JSC Chambers in exchange. This is because his relationship with Mr Lodhia is “long-standing” and, it appears, goes back to when Mr Lodhia was a director of Fit Kitchen Ltd. xi) I do not accept that Mr Lodhia had any liability to pay money to Mr Chiffers for his services. Consistently with this, no invoices have been issued to charge Mr Lodhia for any of the work which Mr Chiffers has done at any stage ([14] Chiffers 2, [33] Chiffers 3). In Chiffers 5 he says that “there were no formal invoices” [21] but the evidence suggests that there were no invoices at all, and Mr Lodhia confirms this. xii) Also consistent with this, Mr Lodhia has not made any payment to Mr Chiffers for work done on this case ([12] Chiffers 2, [33] Chiffers 3).[172]Mr Lodhia has made various attempts to explain his position, and to defend the declaration in the 5 May statement and his conduct in relation to it in witness statements which are verified with a statement of truth: see e.g. his 22nd witness statement dated 17 June 2026, his 23rd witness statement as amended on 6 July 2026 and his 27th witness statement. I am afraid that I did not believe these explanations.[173]As to the £10,000 figure: i) In his 22nd witness statement, Mr Lodhia confirmed that he was liable to pay Mr Chiffers this figure but did not explain how it was calculated. ii) In his 23rd witness statement, he now gave an elaborate explanation of how the figure was calculated. He said that some of the work – 19.25 hours, amounting to £4812.50, for attending on others and work on documents - had mistakenly been double counted in his statement of costs as it was already included in other entries on the statement. The balance of £5187.50 was for Mr Chiffers “fee for advice and conferences across the proceedings”. He therefore intended to file a revised statement of costs with a reduced total figure of £76,724, including VAT. It is worth noting that this is what he did, signing another declaration that he was liable to pay this sum on 18 June 2026 i.e. he doubled down on his false claim that he was liable to pay the sums claimed, including Mr Chiffers £10,000 plus VAT for his services. However, he did not produce any underlying documents to substantiate his account. iii) In his skeleton argument, at [16] and [17], Mr Lodhia advanced a yet further explanation for the £5,187.50. This was that: “16. The balance of £5,187.50 comprises:(a) hearing-attendance fees of £4,500, being three days at £1,500 per day, referable to the two-day preliminary hearing on meaning and one day of trial/and or costs hearing; and(b) advice given in conference on 22 December 2025 being 2.75 hours at £250 per hour (£687.50). 17. The attendance fees at 4(a) (sic) became payable under the Claimant’s agreement with Mr Chiffers upon his instruction for those hearings, notwithstanding that the hearings did not proceed as listed and that Mr Chiffers did not ultimately attend.” iv) In his 27th witness statement Mr Lodhia made attempts to reconcile his account with that of Mr Chiffers, which did not support what he said about there being this agreement. As to whether there was any such agreement, he said there was a “narrow point on which they part company”, namely that Mr Chiffers does not recall any express agreement to this effect. Mr Lodhia said that none was written down, but that does not mean that there was no such agreement.[174]In my email before the hearing on 14 July, and at the hearing itself, I pressed Mr Jones on whether Mr Chiffers could stand Mr Lodhia’s claims about being liable for £10,000 plus VAT, and how this was calculated, up. It is quite apparent from Mr Jones’ responses and the five/six statements of Mr Chiffers that he cannot. I specifically asked about [14]-[18] of Mr Lodhia’s skeleton argument and I pressed Mr Jones about [16] and [17] at the hearing, In his 5th witness statement Mr Chiffers says:
“27. Finally, in respect of Mr Lodhia’s statement of costs submitted to the Court and his explanation of the same in his 23rd Witness Statement and skeleton argument… I note what Mr Lodhia says about his calculation of the fees payable to me. My recollection on fees is that, at the outset, there was discussion about an overall fee of £10,000 if the matter proceeded to a trial. I do not recall further discussions about how that broke down, or whether particular refreshers would be payable even if the trial did not go ahead as Mr Lodhia appears to say. The figure of £1,500 for a refresher is not a fee I recall specifically discussing with Mr Lodhia, but it is fair to say that that has been a frequent refresher fee in my practice…. As a result, perhaps I did mention it, or perhaps Mr Lodhia has picked that fee up from his knowledge of my fees in other cases. I do not know.”
[175]It is notable that Mr Chiffers does not confirm [16] and [17] of Mr Lodhia’s skeleton argument. Standing back, and more fundamentally, Mr Jones emphasises in his skeleton argument that “the discontinuance occurred before [Mr Chiffers] being instructed for any hearing”. Mr Chiffers’ and Mr Lodhia’s evidence is that the January and May hearings never went into Mr Chiffers’ diary because he was not available for either hearing. Mr Jones also emphasised that the reading-in which Mr Chiffers did was not on the basis that he was preparing for a hearing but preliminary reading in order to familiarise himself with the case. Mr Chiffers’ evidence is that he would not be paid in cash for his services and there have been no invoices. All of this is entirely inconsistent with Mr Lodhia’s claim that in any event he was liable to pay cash to Mr Chiffers, still less liable to pay 3 days’ refreshers in the total sum of £4,500 despite the fact that Mr Chiffers had never been available for the hearing, and a total of £10,000 plus VAT in money.[176]Secondly, Mr Lodhia has made various attempts to explain that he was not lying when he told me, at the 6 May hearing, that he had paid Mr Chiffers £10,000. i) In his 22nd witness statement he said:
“6. I have seen that, at paragraph 8 of the Order, it is recorded that I stated in open court that I had paid Mr Chiffers, and when. To the extent that there is any apparent inconsistency between that and the evidence of Mr Chiffers, I respectfully wish to clarify what I understood myself to be conveying. 7. As set out above, my understanding is that, in the context of a statement of costs, fees which are liable to be paid are treated as incurred. I did not draw, and did not intend to draw, a material distinction between fees that had been incurred and fees that had been paid, and any reference I made to having “paid”
Mr Chiffers should be understood in that sense – namely, as a reference to fees properly incurred and payable by me, rather than as an assertion inconsistent with Mr Chiffers' evidence as to the present state of the account between us….” ii) In his amended 23rd witness statement Mr Lodhia said that, having reviewed the transcript (which he had recently received) he recognised that what he had told me was not correct and he apologised. He had conflated liability to pay and actual payment. He put this down to being under pressure in the course of a long hearing and he linked it to his difficulties with concentration, information processing and managing high pressure environments, as referred to in Dr Tsakopoulou’s letters. He also attempted to support this explanation by reference to other exchanges in the transcript and he relied on the fact that this had gained him nothing, and that he had accepted his error as soon as he saw the transcript.[177]I do not accept the evidence in either of these statements. i) The evidence shows that Mr Lodhia was not liable to pay Mr Chiffers any money and never has been. So even if he had merely meant that he was liable to pay £10,000, rather than that he had actually paid this sum, this was untrue. ii) As to whether he meant to say that he had already paid the money, he did. The key exchange was as follows:
“MR JUSTICE LINDEN: You are liable to pay Mr Chiffers are you? MR LODHIA: I am, yes. Well, I’ve paid Mr Chiffers, so MR JUSTICE LINDEN: You’ve paid him the £10,000? MR LODHIA: Yes MR JUSTICE LINDEN: Let me just make a note of that, all right. MR LODHIA: Well, £12,000 because it’s plus VAT”
MR LODHIA: I am, yes. Well, I’ve paid Mr Chiffers, so MR LODHIA: Yes MR LODHIA: Well, £12,000 because it’s plus VAT”

MR LODHIA: Yes

[178]Mr Lodhia was absolutely clear that he had paid Mr Chiffers the sum claimed, and I do not accept that his professed difficulties with concentrating, pressure etc had anything to do with what he told me. There were further references, in the course of the hearing, to him having paid Mr Chiffers e.g. he said “So I have then paid counsel for the advice in relation to those applications” and he appeared to be saying that he had done so in September. Mr Price also understood that Mr Lodhia was saying that he had spent £10,000 instructing counsel and remarked on this in his submissions. Although Mr Lodhia intervened during the hearing to say that he wished to correct things which had been said, or to draw attention to a point, he did nothing to correct Mr Price’s understanding.[179]Later in the hearing, when we were dealing with Mr Price’s application for an order that Mr Chiffers provide an explanation of his involvement in the case, including invoices to confirm his charges, Mr Lodhia said that he was “pretty sure” that Mr Chiffers was “very content” to provide evidence and would not have any issues with doing so. I asked Mr Lodhia:
“He can produce evidence that he invoiced you and you have paid the money as you told me” and Mr Lodhia said “Well, that’s fine. Yes”
. He did not say, for example, that he had misspoken earlier in the hearing and the sum had not in fact been paid. Conclusion[180]I am therefore satisfied that the declaration which Mr Lodhia made in the 5 May statement of costs was false in the respects identified above and that his subsequent witness statements which have sought to support and explain it are also false. He was not liable to pay any of the sums claimed. As will be appreciated, this is a very serious matter in that he made the declaration in a formal court document, and he was seeking to recover substantial sums from the Defendants on a false basis. In addition to this, he has lied to the court about his arrangement with Mr Chiffers in relation to fees and when he told the court, on 6 May, that he had paid Mr Chiffers £10,000 plus VAT for his services.[181]In my view this is an aspect of the case which the Attorney General’s Office should consider. I refer, in particular, to the concerns which I have explained about: false statements verified with a statement of truth and the false declaration(s) in a formal court document claiming costs. THE ISSUE AS TO SERVICE OF MR LODHIA’S FATHER[182]I dealt with this topic at [28]-[36] and [121] of the 1st Judgment but, in short, Mr Lodhia’s application at the beginning of the 6 May hearing was that it could not proceed because, apart from the issue about service of Begbies Traynor, his father had a lasting power of attorney (“LPA”) over his financial affairs and therefore should have been served. Mr Lodhia’s submission was that he was a “protected party” for the purposes of CPR Rules 6.13 and 6.25 i.e. he lacked capacity for the purposes of the Mental Capacity Act 2005. When I asked him whether his father was aware of the litigation, he said that he was. When asked why his father was not at the hearing, then, he said that his father was in hospital, albeit this was just that day, “he has had a prostate cancer scare”.[183]I rejected Mr Lodhia’s argument which, I said, made no sense.[184]At [121] of the 1st judgment I noted that I had raised with Mr Lodhia the possibility of his father providing a witness statement which explained his role in relation to Mr Lodhia’s property and financial affairs, and his awareness and knowledge of these proceedings, and which confirmed that he was unable to attend on 6 May because he was in hospital that day. Ironically, Mr Lodhia resisted this on the basis that his father was aged nearly 80 and should not be drawn into these proceedings. In the light of this, I said that I would not go further than to direct that if any point is to be taken on the failure to serve his father or his mother (who also had a power of attorney), any application should be made within 7 days of my Order and supported by, at least, a witness statement from his father which explained these matters.[185]At [13] of my 18 May Order I directed that:
“Insofar as the Claimant or his father wish to make any application in relation to the Lasting Power of Attorney on which he relied at the 6 May 2026 hearing he must do so by no later than 4.30pm on Friday 22 May 2026 and any such application must be supported by a witness statement made by the Claimant’s father which includes an explanation of why he did not attend the hearing on 6 May and exhibits any relevant documentary evidence.”
(emphasis added)[186]Mr Lodhia did then serve a witness statement, dated 20 May 2026, which purports to have been made by his father, Narendra Lodhia. This confirmed the existence of the LPA and exhibited the document itself (which I had already seen) but his father did not suggest that Mr Lodhia lacked capacity. He said that he “managed” his son’s property and financial affairs on his behalf, including his universal credit payments, and that he was paying his son’s mortgage and rent due under a shared ownership lease. However, no detail was given and nor was any documentary evidence exhibited. On the subject of his non-attendance on 6 May, the statement said “I was attending an urgent medical appointment” but no more, and no evidence of this was exhibited.[187]No application was made on the basis that Mr Lodhia’s father considered that he should have been served and, indeed, no concerns were raised by him about the fact that the 6 May hearing proceeded in his absence. However, by email dated 24 June 2026 Mr Lodhia emailed my clerk to request that the July hearing be listed as a remote hearing. The reasons for that request which he gave were that he was a litigant in person. He had a hidden disability which affects his concentration, information processing and ability to manage high-pressure settings and “It will permit my elderly father, who holds lasting power of attorney to attend if he so wishes to.”.[188]My clerk replied that I would consider his application for a remote hearing nearer the time but that if his father wished to attend remotely he should make a request to do so and should explain why he was not able to attend in person. The history of this passage at arms is recorded in greater detail at [10]-[12] of my Order of 7 July 2026.[189]However, in the event, the application for a remote hearing was not pursued by Mr Lodhia. Nor was any application to attend remotely made by Mr Lodhia’s father and nor did his father attend the July hearing. Mr Lodhia told me that this was because his father was concerned that a costs order might be made against him, and that there was a tension between him and his father about these proceedings. His father has not, so far as I am aware, played any part in these proceedings. Conclusion[190]I considered at the time of the 6 May hearing that Mr Lodhia’s application to postpone the hearing on the grounds that his father had not been served made no sense. Subsequent events have reinforced the fact that it was totally without merit. This was not a serious point, as Mr Lodhia well knew, and it is another example of him wasting the time of the court. I will take it into account in the same way as I take into account his preliminary point that the hearing could not proceed because Begbies Traynor had not been served i.e. on the basis that whether or not it “counts” as an “application” for the purposes of Practice Direction 3C, it is relevant to my decision about whether a civil restraint order should be made. MR LODHIA’S APPLICATIONS FOR PERMISSION TO APPEAL MY 18 MAY DECISION[191]The 1st Judgment was handed down at 10.30am on 18 May. By email to my clerk dated at 12:19pm, so less than 2 hours later, Mr Lodhia applied for permission to appeal. His email attached detailed Grounds of Appeal and a draft notice of appeal. At this stage there were 9 proposed grounds of appeal. On 22 May 2026, I considered and refused that application as well as Mr Lodhia’s application for a transcript of the hearing to be prepared at public expense. I found that “the proposed appeal has no merit at all”.[192]By email to my clerk dated 26 May 2026 and timed at 2:41pm, Mr Lodhia then sent 2 documents: a Grounds of Appeal dated 19 May 2026 (12 grounds pleaded) and an “Updated Grounds of Appeal” (13 grounds pleaded) which was dated 26 May. It appeared (given that they had a Court of Appeal case number) that he had already applied to the Court of Appeal by that date in any event. His email of 26 May suggested that I may wish to reconsider my 22 May Order given that it was based on the Grounds which he sent on 18 May 2026. Although he said that the Updated Grounds were “served” on 19 May they were not sent to my clerk and nor, it appears, were they filed on CE-File. This was the first time I had become aware of them. I declined to consider this application and directed that he apply directly to the Court of Appeal.[193]I note from Ms Yates’ 8th witness statement that Mr Lodhia appears to have sent his first Grounds of Appeal to rradar at about the same time as he sent it to my clerk. Thereafter, he sent rradar 6 “updated” Grounds of Appeal: on 19 May at 10:55, 11:53 and 15:01, on 26 May at 14:41, on 27 May 2026 at 10:00, and on 28 May 2026 at 15:08. It appears from the 13 July Order of Miles LJ, refusing permission to appeal, that the final version of Mr Lodhia’s Notice of Appeal contained no fewer than 16 grounds of appeal, none of which (Miles LJ held) had a real prospect of success.[194]At the July hearing I indicated to Mr Price that I was not minded to certify that Mr Lodhia’s first application to me for permission to appeal was totally without merit, even though my view was that it had no merit at all for reasons which I explained in refusing it. Mr Price also confirmed that the Court of Appeal had been asked to find that Mr Lodhia’s application for permission was totally without merit and Miles LJ had not said that it was. In these circumstances it seemed to me that I should be slow to certify that a challenge to my own judgment was totally without merit given that ultimately this would be a view about my own decision which Mr Lodhia should be given latitude to challenge, rather than being deterred from doing so by the threat of this being relied on as part of an application for a civil restraint order.[195]On reflection, that remains my view. But it does seem to me that I should certify that the 26 May 2026 application to me was totally without merit, rather than the first application as Mr Price contended. By now, I had refused Mr Lodhia’s first application for permission. He had appealed to the Court of Appeal, which was seized of the matter, on the basis of expanded grounds of appeal. There was no basis on which it would be appropriate for me now to revisit the matter and grant permission having previously refused it. He also asked me to reconsider on the basis of two different versions of his Grounds of Appeal. The issue here is not that Mr Lodhia challenged my decision; it is the fact that, having been refused permission he wanted to have another “go” based on a different version of his case. This wasted the time and resources of the court. MR LODHIA’S APPLICATION OF 25 JUNE 2026[196]In view of Mr Lodhia’ approach of sending the court multiple emails, witness statements and other documents at [6] the 19 June Order specified that:
“Any further evidence or applications for the purposes of the Hearing will be filed and served by 4pm on Friday 3 July 2026. Insofar as the Claimant proposes to rely on any further witness statement made by him, he is permitted to rely on one further application notice and one further supplemental witness statement of his…which deal with all additional matters. This statement will not repeat or replicate evidence contained in the witness statements which the Claimant has already served in these proceedings and, if it does to a material extent, the Court may decline to consider it…”
[197]The letter and spirit of this was ignored by Mr Lodhia. My clerk received in the order of 76 emails from him in the period from 19 June to 14 July. These included an application notice dated 25 June 2026. In his covering email Mr Lodhia was bold enough to express concern that I had not read his witness statements and had been ordering him to do things which he had already done, and he asked me to stay the 19 June Order pending determination of his application.[198]The relief sought in the draft order attached to Mr Lodhia’s 25 June application was that I decline to initiate proceedings for contempt of court against him; that I direct that any allegation of contempt of court be pursued, if at all, by the Defendants making an application to commit him pursuant to CPR Part 81; that if the Defendants wished to cross examine him they should make a formal application to do so “such application to be determined by the Court afresh in the light of the evidence now before it”; that any such application should be served “on the Claimant and on each non-party against whom allegations are made”; and that the July hearing be vacated or conducted as a remote hearing. The application notice stated that he wanted the application itself to be listed and heard as a remote hearing.[199]This application was wholly unnecessary and unreasonable. For the most part it addressed issues which were to be determined at the July hearing, and there was no need to determine them in advance of that hearing. I had also already said, in my Reasons for the 19 June Order, that “Mr Chiffers and the Claimant will have the opportunity to give oral evidence at the Hearing if they wish to supplement their written evidence on oath or under affirmation, and the Court will consider any application to cross examine them”. And I had set a deadline for any applications. I could see no reason why the hearing should be postponed or conducted as a remote hearing.[200]In the course of the exchanges between Mr Lodhia and the court I therefore asked my clerk to send him an email (cc the parties) which said the following:
“Linden J is not prepared to enter into daily correspondence with you and this is why he made the Order which he made, requiring you to submit one application, by 4pm on 3 July, which includes all of the orders or directions which you wish him to make. You will need to decide whether your application of 25 June is that one application, in which case Linden J will make an Order in relation to it. If you envisage further applications before 4pm on 3 July 2026 please say so, withdraw the application of 25 June 2026, and then comply with paragraph 6 of the 19 June Order by making one application which covers everything, before the stated deadline. It is important that you do so, so that your position as to what you want the Court to do is fully considered.”
[201]By email dated 26 June, Mr Lodhia then wrote restating the list of issues which were already identified in my 19 June order. He said that on the proviso that these were the issues (which they obviously were), he withdrew his 25 June application. This tended to confirm the pointlessness and lack of merit of that application which, again, wasted the time of the court and the parties.[202]I refused Mr Lodhia’s application dated 25 June in my Order of 7 July 2026. In the context of the case as a whole, and in the light of subsequent events including Mr Lodhia’s subsequent applications (which did not pursue key aspects of the 25 June application but which clearly show that he was ignoring my directions of 19 June), I am satisfied that that application was totally without merit. MR LODHIA’S 3/10 JULY APPLICATIONS[203]Mr Lodhia made 2 applications which are dated 3 July 2026, although he sent the second one to my clerk on 10 July.[204]His first application was a N244 application notice. The relief sought included that the court: i) strike out or give no weight to Ms Yates’ 8th witness statement (which gathered together the evidence against him); ii) decline to initiate contempt proceedings against him or alternatively require the Defendants to make a Part 81 application or refer the matter to the Attorney General; iii) declare that his 10th witness statement was withdrawn and “not having borne a compliant statement of truth was invalid”; iv) should not determine whether he was guilty of contempt of court; v) stay any question of contempt of court against him pending his appeal to the Court of Appeal; vi) consider initiating proceedings for contempt of court against Ms Yates based on his allegation that she had made false and misleading statements in her 7th and 8th witness statements; vii) further or alternatively, refer Ms Yates and/or rradar Limited to the Solicitors Regulation Authority (“SRA”) pursuant to the Hamid jurisdiction; viii) permit him “and/or his counsel, if instructed” to cross examine Ms Yates; ix) determine his application “before any other matter is determined.”[205]I note (from (iii) above) that Mr Lodhia persisted in the hope that he could persuade the court that because he had withdrawn his 10th witness statement, and his statement of truth and not been in the standard terms, it should ignore the fact that his evidence was false. I had also already made clear, in the 19 June Order and subsequent email correspondence, that I would not decide whether Mr Lodhia was in contempt of court; only whether proceedings should be initiated against him. And I had refused a stay at the time of refusing permission to appeal. These aspects of his application therefore lacked merit.[206]In addition to this, the 3 July application was supported by Mr Lodhia’s 26th witness statement v30 dated 3 July. Over the course of 26 pages, he set out his stall including a detailed an unfounded attack on Ms Yates in relation to her professional conduct in the course of the proceedings, and on the veracity of a number of things which she had said, in the correspondence between the parties and her witness statements.[207]Mr Lodhia’s second application was a N600 application notice to commit Ms Yates for contempt of court which was submitted at 2:55pm on 10 July. The basis for this application was said to be that Ms Yates had made false and deliberately misleading statements in witness statements which were verified with statements of truth, as alleged in his N244 application notice and 26th witness statement. Mr Lodhia said that he had been advised by court staff to submit such an application if he was seeking to commit Ms Yates for contempt of court.[208]In his skeleton argument, Mr Lodhia said that cross examination of Ms Yates would take 1.5 to 2 hours. Although his application notices were directed at her, in the email correspondence and in his skeleton argument, Mr Lodhia stated that if the Defendants were to place reliance on any correspondence written by Ms Matusiewicz (and he estimated that 90% of it was) she should verify that correspondence on oath and make herself available for cross examination at the hearing. He said that he understood that Ms Matusiewicz “has arranged annual leave over the hearing dates” but if her letters and emails were relied on (as he knew they were) he would invite the court to direct her to attend or alternatively adjourn the issues to which her correspondence was relevant. By email, he suggested that she could be cross examined remotely but said that he wanted me to record any decision in this regard “in a sealed order, with brief reasons, so that it can be the subject of an urgent application to the Court of Appeal before the hearing if necessary” (see his email to my clerk of 10 July 2026 at 2:47pm enclosing the N600 committal application).[209]It is not necessary to spend a great deal of time on these applications as ultimately they were not pursued by Mr Lodhia. For various reasons, however, they were both totally without merit, as his withdrawal of them confirmed. The reasons include that the evidence of Ms Yates and the correspondence of Ms Matusiewicz to which he took exception was effectively the case against him, which I have found to be established on the evidence. His application to exclude Ms Yates’ 8th witness statement was transparently a tactical manoeuvre to exclude the evidence against him for the purposes of the July hearing. Moreover, his application to cross examine Ms Yates was tactical rather than genuine because her 8th witness statement did no more than report what was in the documents which were before the court and invite certain conclusions to be drawn from them. Cross examination of her would be of no assistance to the court. His suggestion that Ms Matusiewicz be required to attend for cross examination etc was a similar tactical manoeuvre.[210]The 3 July applications also formed part of a pattern of “playing the woman not the ball” which had been apparent since much earlier that the proceedings. In the correspondence with rradar he made a number of baseless allegations of professional misconduct and threats (on JSC Chambers headed notepaper) to make complaints to the SRA about their conduct of the proceedings. Indeed, at the hearing he told me that he had made a complaint to the SRA and even had the audacity (in an email to my clerk at 8.37am on the second day of the hearing) as to ask me for guidance on whether his understanding of the SRA procedure was correct. It appears from email correspondence which he exhibits to his 27th witness statement that he did indeed file a complaint against Ms Yates with the SRA. I note that he did so on the afternoon of 7 July 2026, in my view as a litigation tactic.[211]I was also shown a JSC Chambers letter of claim dated 28 January 2026 which set out a proposed claim against rradar and against Ms Yates and Ms Matusiewicz personally. It is apparent from the evidence that Kennedys are instructed on their behalf. Mr Lodhia told me at the July hearing that he had filed a claim form against them which, I was told, included a claim for defamation. This appeared to have been shortly before the hearing as he told me that he was awaiting the sealed copy which he would then serve.[212]A flavour of Mr Lodhia’s continuing obnoxious approach is perhaps illustrated by the following passage from an email to Ms Yates and Ms Matusiewicz on 6 July 2026 (cc Mr Lazarev and Mr Chiffers):
“3. Costs and appellate position Your clients should note that two appeal hearings are currently in train in relation to this matter, with a third likely to follow. Quite apart from the personal claim against Ms Yates and Ms Matusiewicz for breach of contract, the unbillable time and the costs now being incurred – by them and by rradar as an organisation – are, and will remain, wholly disproportionate and, on the Claimant’s case, will not be enforceable. It is the Claimant’s understanding that the TTMC Defendants have already exhausted their indemnity limit in these proceedings, in large part as a consequence of the conduct of the litigation by Ms Yates and Ms Matusiewicz. You and your clients would be well advised to give careful consideration to your respective positions in light of that exposure, particularly insofar as it concerns Ms Yates. For the avoidance of doubt, should the contempt application be refused, that order will be appealed to the Court of Appeal and, if necessary, beyond. Your clients should be under no illusion: the Claimant intends to pursue the claims and allegations concerning Ms Yates unreservedly, through every lawful channel available to him, given the clear public interest engaged.”
[213]That Mr Lodhia should behave in this way is all the more concerning when one considers that he knew that his conduct was very much under scrutiny by the court and that there were serious concerns. Notwithstanding this, there was no sign of reflection or contrition on his part right up to the second day of the hearing. His conduct throughout the proceedings, aspects of which bordered on harassment of Ms Yates and Ms Matusiewicz for doing their jobs well, showed very poor judgment. But this was particularly so in relation to his behaviour after my 18 May decision.[214]However, following the mid-session break on the second day of the July hearing Mr Lodhia said that he was no longer pursuing his 3 July applications. This was a remarkable volte face given the correspondence in the run up to the hearing. He said various things by way of explanation of this change of heart, including that he wasn’t feeling very well and that this would affect his ability to cross examine, although he was clearly fully able to make submissions and did not suggest that he was unable to do so. He also said that he felt that “things had gone too far” and that he now intended to withdraw his claim against the solicitors for the TTMC Defendants and his complaint to the SRA so that the only remaining live claim in which he was involved as a party was related to proceedings in the First Tier Tribunal. His submissions continued and, after the lunchtime adjournment, he told me that he had apologised to Ms Yates.[215]In his 27th witness statement, Mr Lodhia confirms that he has withdrawn his claim against TTMC’s solicitors and the SRA complaint. These developments were no doubt welcome but I am afraid that, again, they had a distinctly tactical flavour and smacked of a damage limitation exercise when he sensed that his strategy to date was not working. I note that at the same time Mr Lodhia argued that no civil restraint order should be made against him and, instead, it will be sufficient for him to give a “Confidential Undertaking” to the court that he will seek consent of the court for certain litigation activities. Mr Lodhia’s volte face tends to confirm that the 3/10 July applications were totally without merit and it does not mean that the court or anyone else can now ignore the very serious misconduct on his part which I have found to have taken place. REFERRAL TO A REGULATORY BODY?

Context

[216]I am told that Mr Chiffers and Joseph Chiffers Barrister at Law Limited (t/a JSC Chambers) are authorised by the Bar Council and the Bar Standards Board (“BSB”) to conduct litigation and direct access work. Mr Chiffers’ evidence is that Mr Lodhia is “a legal consultant engaged by the limited company and supervised by” Mr Chiffers. Mr Lodhia has no legal qualifications, and I am told that he himself is not regulated although the BSB may wish to check this.[217]Mr Chiffers says that Mr Lodhia has, however, provided legal support services and has exercised rights of audience. Mr Chiffers says that this is on the basis that Mr Lodhia is exempt because the hearing is in private and he is supervised by a qualified person. I have also seen, in the evidence, at least 2 decisions of the First-Tier Tribunal Property Chambers (Residential Property) where Mr Lodhia has appeared as the advocate at what appears to be a public hearing. In one of these (LON/00BG/LRM/2026/0011) he is recorded as “Representative: Mr Amar Lodhia, JSC Chambers”. Mr Lodhia’s entry on the JSC Chambers website says that he is “a keen advocate, holding full rights of audience in tribunals and the County Court, with supervised advocacy rights in the higher courts.” and that he represents “leaseholders in complex Right to Manage proceedings and related property litigation.”[218]There is also an undocumented arrangement between Mr Lodhia and JSC Chambers whereby Mr Lodhia is paid 50% of any sums recovered from a client who was introduced to JSC Chambers by him (whether by way of fees or costs recovered from the other side). Mr Lodhia appeared to be saying that he understood that this arrangement applied in the present case and was part of the explanation for his 5 May statement of costs.[219]In his 4th witness statement, Mr Chiffers gives further detail as to what he says are Mr Lodhia’s activities at JSC Chambers. This evidence emphasises that Mr Lodhia performs basic tasks under supervision but I have to say that the evidence in this case indicates that he does more than this. I also have considerable doubts that he is properly supervised if he is supervised at all. Mr Chiffers’ evidence about whether there are clear systems and rules in place governing Mr Lodhia’s litigation activities is unimpressive. In the context of this case, it is noteworthy that these activities include drafting witness statements for Mr Chiffers to approve. I also note that Mr Chiffers says that “the decision on whether JSC will be involved in conducting litigation in any particular matter is always made by me and this has been made explicit to the Claimant and all staff at JSC”. He says the same thing about threats of referrals to the regulator or complaints against lawyers, which he says must be approved by him if made in the name of JSC, and he says that JSC email addresses are controlled by him via an IT consultant. The evidence which I have seen in this case suggests that if there are rules to this effect they are not clearly written down and they are not enforced. The submissions on behalf of Mr Chiffers[220]On instructions, Mr Price did not make submissions on the question of a regulatory referral. Mr Lodhia gave his evidence and made submissions about his and Mr Chiffers’ respective roles: in effect, that whatever the JSC letters may have said, it was clearly understood by the Defendants that he was a litigant in person.[221]Mr Jones submitted that I could not and should not refer Mr Chiffers or JSC Chambers to the BSB for the following key reasons: i) Mr Chiffers is not “before the court” whereas, Mr Jones submitted, the Hamid jurisdiction is concerned with dealing with conduct of claims and applications by practitioners before the court, which the court considers to amount to an abuse of its processes: see R (Hamid) v Secretary of State for the Home Department [2012] EWHC 3070 (Admin). ii) The Hamid jurisdiction does not permit the court to refer a practitioner absent a finding that they have committed a regulatory breach in conducting proceedings before the court whereas Mr Chiffers had not committed any regulatory breach: see Kamal v Tax Policy Associates [2026] EWHC 551 (KB) at [30]. iii) In any event, Mr Chiffers had self-referred to the BSB and a referral by the court was therefore unnecessary: compare Gubarev v Orbis Business Intelligence Ltd [2020] EWHC 2167 (QB), [2020] 4 WLR 122 at [65].[222]As far as the first point is concerned Mr Jones noted that, whilst the scope of the Hamid jurisdiction has expanded over the years, there is no precedent for a referral of a lawyer in respect of a matter in which they have not acted, or on matters going to their practice generally. He submitted that the Hamid jurisdiction has only ever been used in respect of a practitioner who actually appeared before the court at a hearing or made a specific application and, in doing so, breached the relevant rules. It has never been used to call into question a practitioner’s general practice of their profession as opposed to their specific conduct of a particular case.[223]Mr Jones emphasised his case that Mr Lodhia was conducting his own case. This is not a case in which Mr Lodhia was providing litigation support services to JSC Chambers. This necessarily meant that Mr Chiffers was not supervising him in the way that he would supervise other JSC client work carried out by Mr Lodhia. Mr Chiffers was also involved in the present case on a direct access basis to perform particular tasks, rather than conducting the proceedings on Mr Lodhia’s behalf. Again, this meant that he was not supervising Mr Lodhia as such and was not in a position to countermand steps which Mr Lodhia chose to take or approaches which he adopted to the litigation and in the correspondence. Nor, in the vast majority of instances, was he even aware of what Mr Lodhia was doing. Discussion[224]The thrust of Mr Chiffers’ evidence in support of the submission that he was not sufficiently involved in this matter to be held accountable for any of Mr Lodhia’s actions is that: i) Although Mr Chiffers had frequently been copied in on emails and other correspondence which Mr Lodhia was sending to the Defendants from his JSC Chambers email address, as “Amar Lodhia Legal Consultant” and/or JSC Chambers and/or on JSC Chambers headed notepaper, he had not reviewed or approved these communications. It also appears that his evidence is that he had not read them given his professed ignorance of what was going on. ii) Mr Lodhia had frequently made use of JSC Chambers headed notepaper in the correspondence but, again, he did this without the knowledge or authorisation of Mr Chiffers. Mr Chiffers may have been copied in on some of the JSC Chambers letters but, again, his evidence appears to be that he did not notice that Mr Lodhia was claiming that he was represented by JSC Chambers. iii) Mr Lodhia’s frequent representations that JSC Chambers were on the record and/or acting for him were inaccurate and, in any event, the Defendants knew that JSC Chambers were not really acting for him. Again, Mr Chiffers was not aware that he was making these representations or, at least, did not register that he was. iv) There were two sets of written submissions – one in support of the application to postpone the January 2026 hearing, and the other on the subject of costs – one of which had been signed “JSC Chambers…Direct Access Counsel for the Claimant” and gave the email address for the clerks at JSC Chambers. But neither had in fact been written by Mr Chiffers. v) Mr Lodhia had repeatedly threatened claims and made complaints against the solicitors for the Defendants on JSC Chambers headed notepaper, but these letters had not been reviewed or approved by Mr Chiffers, and Mr Lodhia did so contrary to a clear general instruction that he was required to seek prior authorisation. vi) Although Mr Chiffers’ signature appeared on the 22 April 2026 application notice, he had not signed it and did not know how his signature came to be there. He had not reviewed the evidence which Mr Lodhia was sending to the Defendants at that time, or which was filed in support of the application, and he was unaware that Mr Lodhia was sending false and/or fabricated evidence and had said under a statement of truth in the 10th and 11th witness statements that they were “Prepared by: JSC Chambers (Joseph Chiffers Barrister at Law Limited)”. vii) Nor did Mr Chiffers have any knowledge of the statements of costs submitted by Mr Lodhia, including the 5 May statement of costs, which declared that Mr Lodhia was liable to pay substantial sums, including to Mr Chiffers, which Mr Chiffers says, in effect, he was not liable to pay. viii) Mr Chiffers had never appeared at a hearing in the case. ix) Nor did Mr Chiffers have any knowledge of correspondence on 24 May 2026 on JSC headed notepaper, giving his email address, which began “We write to inform you that this firm has been instructed by [Mr Lodhia’s parents] in their capacity as attorneys under [a LPA]….”. x) And nor did he have any knowledge of the fact that Mr Lodhia sent Mr Chiffers’ first witness statement to Begbies Traynor on 2 June 2026 and relayed to them that Mr Chiffers had told him that the email correspondence which Ms Cramphorn had been ordered to provide to the court “is privileged and does not need to be disclosed”. In a subsequent email to Ms Cramphorn that day, Mr Lodhia reiterated that “litigation and legal privilege” applied and, appeared to be suggesting to Ms Cramphorn that there was little risk for her in failing to comply with my[225]Mr Jones did not disagree with my characterisation of his case as being that Mr Lodhia had “gone rogue”. And to a large extent Mr Lodhia appeared to be saying that he did indeed act without Mr Chiffers’ knowledge or authority, albeit he did so in good faith and as a result of inexperience and/or AI doing things which he had not instructed it to do. In his 27th witness statement, Mr Lodhia also presses the argument that all concerned understood that he was a litigant in person. At the same time, he says that he genuinely believed that JSC Chambers had filed a notice of acting when he said this to the Defendants’ solicitors. He says that he did not put Mr Chiffers’s signature on the 22 April application notice and that JSC Chambers are genuinely instructed on behalf of his parents, even if Mr Chiffers is unaware of this.[226]Having considered the evidence and the competing arguments, I am satisfied that I should refer Mr Chiffers and JSC Chambers to the Bar Standards Board. It will be a matter for the BSB to consider how widely they wish to investigate practices at JSC Chambers but, at the very least, they should investigate what happened in this case in terms of Mr Chiffers’ knowledge of Mr Lodhia’s activities and whether there was a failure of supervision or any other regulatory breach. It will be for them to consider whether they accept Mr Chiffers’ and Mr Lodhia’s evidence in this regard. My concerns include the question whether the following Rules of the Bar Code of Conduct may have been broken: C87, C88, C89 (particularly 89.1 and 89.6) C90 and C94 (particularly 94.2, 94.3, 94.8). For this purpose, as a starting point, the BSB should be provided with my judgments and orders and the evidence and other materials, including written arguments which I have considered for the purposes of both hearings.[227]I see the force of Mr Jones’ submission that I should not order a roving inquiry into JSC Chambers and I do not do so. However, given that I am exercising the inherent jurisdiction of the court to prevent abuses of its process, I do not accept that I am circumscribed by vague rules such as that a practitioner must be “before the court” if the court is to be able to do anything about regulatory concerns in relation to them. I am quite sure that, for example, in the event of misconduct by a junior lawyer (though Mr Lodhia is actually 42 years of age) who was said to be supervised by a partner who was not actually at the hearing or on the court documents, the court could refer the partner for consideration of whether there had been adequate supervision of the junior lawyer.[228]But, in any event, there seems to me to be plenty of evidence that Mr Chiffers and/or JSC Chambers were sufficiently “before the court” for it to be appropriate for them to be asked by the regulator to explain their own position in relation to Mr Lodhia’s actions, and their involvement in those actions. Mr Lodhia is engaged by the company and was corresponding as JSC Chambers and repeatedly representing that Mr Chiffers and/or “the firm” were acting for him in correspondence with the Defendants and with the court. Mr Chiffers’ signature is also on the 22 April 2026 application and the circumstances in which it came to be there have not been established. That application was very much “before the court” and it caused a very serious interference with the administration of justice.[229]Mr Chiffers evidence is, in effect, that Mr Lodhia was virtually unsupervised in the context of the present proceedings and his dealings with the Defendants and third parties, and acted without authorisation. If right, that is a concern in itself given what happened in this case. But there remains a very real issue as to what exactly Mr Chiffers’ role in this case was and, in my view, this needs to be considered as part of the BSB investigation. Although Mr Chiffers has been more forthcoming in his 5th witness statement, I am afraid that his overall response to my Order of 18 May has not been satisfactory. Given that he was the subject of an order of the court, in my view he was sufficiently “before the court” from that point even if, contrary to my view, before this he was not. Quite apart from being the subject of a court order, he was also obliged by his professional code of conduct “to act with independence in the interests of justice” (Rule C3 of the Code of Conduct) and not do anything which could reasonably be seen by the public to undermine his integrity or independence (C8).[230]Until his 5th witness statement, Mr Chiffers’ evidence was strikingly vague as to what work he had actually done on this case and even now it retains a certain vagueness. For example, in his first statement, dated 2 June 2026, he said “the nature of any retainer between JSC and the Claimant would be privileged in my view” and that the terms of his engagement including “any conditional fee arrangements and any payments made by the Claimant are legally privileged” (emphasis added). In other words, he was not even prepared to commit himself on whether there was a retainer or conditional fee arrangement or whether there had been any payment to him. He gave some very vague information about his involvement in the proceedings but, rather than verify the position stated by Mr Lodhia in the 5 May statement of costs (or contradict it), he simply relayed the explanation which Mr Lodhia had given to him. He said he was not aware of any other matters which he believed the court should be aware of, but there plainly were.[231]In my Order of 10 June 2026 I said that it was not clear to me that Mr Chiffers had appreciated the seriousness of the situation and that in my provisional view he had failed to comply with my Order of 18 May 2026. I gave, as a clearcut example, the fact that he had been ordered to confirm that Mr Lodhia was liable to pay the fees claimed in the 5 May statement of costs, and yet he had merely stated what he had been told by Mr Lodhia. I also queried his claim that privilege applied to the information which he had been ordered to provide. I therefore ordered him (amongst other things) to explain, in a witness statement signed with a statement of truth, the basis on which he considered that privilege applied, and to confirm the truth or otherwise of what he said Mr Lodhia had told him and “on what basis the Claimant is liable to pay the sums claimed in his statement of costs dated 5 May 2026.”[232]This resulted in Mr Chiffers’ 2nd witness statement dated 17 June 2026 which he subsequently, and apparently hastily, amended on the next day to provide further information. Both documents remained vague. In his composite amended 2nd statement, Mr Chiffers said that “on reflection” he accepted that privilege did not apply to a retainer between a lawyer and a client, and that he had simply assumed that it did. He said that he had reviewed my Order of 18 May to “see whether I should disclose any additional information”. He noted that he was not specifically asked to disclose the details of “any” retainer but did not say whether one existed and did not disclose one. Again, he appeared to be unwilling to disclose the true position despite being subject to a second order of the court. It was not until his 5th witness statement that he finally accepted that he did not have a direct access retainer letter for the purposes of his work on this case.[233]I do not suggest that Mr Chiffers failed to provide important information which was relevant to the issue about the 5 May statement of costs – I have been able to make findings based on his evidence - but a certain amount of reading between the lines has been required when this should not have been necessary. Statements such as that Mr Lodhia “would be liable for the time I personally spent advising and assisting him” ([18] Chiffers 2) and Mr Chiffers’ overall approach in his five/six statements suggested that he was trying to ride two horses - to protect himself and to protect Mr Lodhia – and was therefore choosing not to be direct or specific. In his 4th witness statement he again said that “I am prevented by litigation privilege from giving a more detailed description of the work I have carried out”. How litigation privilege prevented him from complying fully with my Order, and in one statement rather than five/six, has never been explained. His desire to protect Mr Lodhia, if that is the reason for his approach, may show loyalty but it may not sit well with his regulatory responsibilities. Moreover, his approach has not inspired confidence that he takes his responsibilities as a regulated individual and supervisor of others sufficiently seriously.[234]I also do not accept Mr Jones’ submission that I cannot refer this case to the regulator unless I have found a regulatory breach by Mr Chiffers. Nor do I agree with Mr Jones that it is the practice of the court, under the Hamid jurisdiction or otherwise, to do so in every case if there is to be a referral. The court may do so in a given case, but often it will make findings about what happened and then refer the practitioner for consideration of whether there has been a breach of regulation and, if so, what the consequences should be. Where the precise facts are uncertain or disputed, the court will not necessarily make findings on all matters and may well leave factual issues for the regulator to determine. Indeed, the ability to carry out a full investigation and, for example, issues of privilege may mean that the regulator is better equipped than the court to do so.[235]As it happens there were clear regulatory breaches by Mr Chiffers, as he accepted in his 5th statement i.e. that he was acting on a direct access basis without any written agreement as to the terms on which he was doing so: see Rule C125. Nor, it appears, did he keep the case record required by Rule C128 or comply with C129. But, in any event, I consider that the inherent jurisdiction of the court enables me to refer a case for investigation as to whether there has been a failure to comply with regulatory requirements, especially where, as here, there is uncertainty as to the precise factual position and the BSB will be better able to carry out the necessary investigation and to ascertain the full facts of what occurred and what consequences, if any, should follow.[236]I agree with Mr Jones that the court may conclude that it is not necessary to refer a matter to the regulator where there has been a self-referral but, again, that is not a rule. In R (Ayinde) v Haringey London Borough Council [2025] EWHC 1383 (Admin), [2025] 1 WLR 5147 at [70] and [81], for example, the court also referred a barrister and a solicitor notwithstanding that they had self-referred. Where a court has confidence that the issues have been fully taken on board and that it can depend on a self-referral to result in the issues being fully considered, and appropriate action being taken, no doubt it will see no need, itself, to refer a matter to the regulator.[237]However, that is not the position here. Apart from the points which I have made above, as to Mr Chiffers unsatisfactory responses to the orders of the court, I have read his self-referral and do not consider that it adequately reflects the seriousness of what has happened in this case. For one thing, it was not made until 13 July i.e. the day before the July hearing, despite the fact that the issues in relation to Mr Lodhia’s conduct came to Mr Chiffers’ attention shortly after 18 May. For another, the referral takes the form of an email which reads, so far as material, as follows:
“In a matter where Mr Lodhia was the Claimant/a litigant in person, he has been accused of misleading the Court on a number of separate matters. He denies these allegations and a hearing is set for this Tuesday to determine whether he will be subject to committal proceedings. The judge is also considering a Hamid referral for myself based on a failure to supervise Mr Lodhia. However, my position is that there can be no basis for any such referral because Mr Lodhia was a litigation (sic) in person (who has an unfettered right to conduct litigation as per sch 2(4) LSA) in the relevant case, and I only assisted him when requested to do so. My question is, based on the present situation, is or should there be, any restriction on Mr Lodhia continuing to provide us with his services, bearing in mind that the allegations are denied and unproven? At present no new matters will be created, where he will act as a consultant, without my express approval. I would also like to discuss supervision more generally at a mutually convenient time. I will provide you with some documents at the next opportunity to assist you in understanding the background to the matter.”
[238]I note the pre penultimate and penultimate paragraphs. My written question for Mr Chiffers as to what else he has done given the concerns which the Court has raised, has gone unanswered in his 5th witness statement. Mr Chiffers has not given evidence of any positive steps to ensure that there is no reoccurrence of Mr Lodhia’s behaviour and the evidence suggests that he is, if anything, supportive of Mr Lodhia and his denials. Perhaps as a consequence, despite the 18 May judgment, Mr Lodhia’s pattern of behaviour in relation to these proceedings continued right up to the July hearing.[239]Indeed, on 21 July 2026 Mr Lodhia filed a winding up petition “c/o JSC Chambers” in relation to Urang (case no CR-2026-005662). This relates to a statutory demand which Mr Lodhia served on 23 June 2026 and the statutory demand relates, in part, to the sum of £840 which he was awarded in case number KB-2026-000549 and which, he knew when he issued the petition, is the subject of Urang’s set off application. In the winding up proceedings, Mr Lodhia has also signed statements of costs on 12 and 19 June 2026 on the basis that he is a “Partner” in JSC Chambers, and he claims a further £18,292. These costs include fees for Mr Chiffers and fees which he apparently alleges he is liable to pay JSC Chambers including for his own work and the services of Mr Chiffers assistant, Tracey Johnson. The costs are subject to detailed assessment and therefore the amounts claimed in the winding up petition are not liquidated or due. Conclusion[240]I am afraid that I do not have confidence that Mr Chiffers has matters in hand. So for all of these reasons, I propose to refer Mr Chiffers and Joseph Chiffers Barrister at Law Limited (t/a JSC Chambers) to the Bar Standard Board for investigation of the concerns addressed in the 1st Judgment and this judgment. CONCLUSIONS ON THE ISSUES The costs of the 6 May hearing[241]I accept Mr Price’s submission that the Defendants were wholly successful and that costs should follow the event. Mr Lodhia did not seriously contest this, but he submitted that I should make a reduction in the costs which he was ordered to pay so as to reflect the Defendants’ conduct. He gave as an example the fact that their time estimate of half a day was inadequate, as I pointed out in the 1st Judgment.[242]I do not accept that there was any conduct of the Defendants in relation to the 6 May hearing which unnecessarily increased the costs of that hearing. It was Mr Lodhia’s conduct in taking a number of hopeless points which did so. Nor was there any conduct of the Defendants which would otherwise justify a reduction.[243]I propose to order that Mr Lodhia pay the costs of the 6 May hearing.[244]Mr Price confirmed that the TTMC Defendants did not seek any additional payment on account of costs, so there is no need to revisit this aspect of my Order of 18 May. The basis for assessment of the Defendants’ costs[245]As is well known costs, including the basis for assessment, are in the discretion of the court: see CPR Rule 44.2(1). Rule 44.2(4) provides that in deciding what order to make about costs that court will have regard to all the circumstances including(a) the conduct of the parties;(b) whether a party has succeeded on its case and(c) any admissible offer to settle. Rule 44.2(5) then identifies what the conduct of the parties may include as follows:
“(a) conduct before, as well as during, the proceedings and in particular the extent to which the parties followed the Practice Direction – Pre-Action Conduct or any relevant pre-action protocol; (b) whether it was reasonable for a party to raise, pursue or contest a particular allegation or issue; (c) the manner in which a party has pursued or defended its case or a particular allegation or issue; …”
[246]In Thakkar v Mican [2024] EWCA Civ 552, [2024] 1 WLR 4196 at [19], Coulson LJ helpfully summarised the applicable principles as follows (I have omitted his reference to authority): “(a) The discretion to award indemnity costs is a wide one and must be exercised taking into account all the circumstances of the case, including but not limited to the conduct of the paying party… (b) In order to obtain an order for indemnity costs, the receiving party must surmount a high hurdle; to be able to demonstrate “some conduct or some circumstance which takes the case out of the norm. That is the critical requirement”…Whilst it is preferable for the judge expressly to apply the test of “out of the norm”, the use of the word “exceptional” may be consistent with the judge having applied the principles…. (c) To the extent that the application is based on the paying party's conduct, it is necessary to show such conduct was “unreasonable to a high degree” in order to recover indemnity costs…but it is not necessary to go so far as to demonstrate “a moral lack of probity or conduct deserving of moral condemnation” on the part of the paying party…. (d) Merely because the conduct in question may happen regularly in litigation does not mean that such conduct cannot also be “out of the norm”…the word ‘norm’ was not intended to reflect whether what occurred was something that happened often so that in one sense it might be seen as ‘normal’ but was intended to reflect something outside the ordinary and reasonable conduct of proceedings”….[247]For the reasons given above and in the 1st Judgment, I am satisfied that Mr Lodhia’s conduct of the proceedings was indeed “out of the norm”.[248]As far as the 1st Judgment is concerned, I made various findings that Mr Lodhia’s conduct of the proceedings was unreasonable: see, e.g. [57], [68], [73], [77(i)] and I found that he had put forward a number of “hopeless” arguments to the effect that he should not have to pay the costs on discontinuance: see [93]. He also put forward disingenuous arguments that the 6 May hearing could not go ahead because the Trustees and his father had not been served. I also accept Mr Price’s submission that I should take into account the fact that Mr Lodhia: i) Aggressively pursued allegations of malice against the TTMC Defendants (i.e. allegations tantamount to dishonesty) and then abruptly abandoned them without explanation. ii) Appeared to be determined to undermine the relationship between the TTMC Defendants and their insurer as part of his litigation strategy. iii) Again as part of his litigation strategy, unreasonably threatened the TTMC Defendants’ legal representatives with regulatory complaints and/or claims against them personally and, indeed, followed through on these threats. iv) Misled the Defendants in relation to the alleged judgment of Master Dagnall in claim number QB-2022-0000089 and wasted their time by relying on it but refusing to produce it rather than tell them that it did not exist.[249]As I have found, Mr Lodhia’s conduct of the proceedings also involved a number of applications which were totally without merit, various hopeless arguments, a high handed and aggressive approach to the correspondence which was unnecessarily voluminous, unfounded allegations of bad faith against the TTMC Defendants’ lawyers, reliance on false evidence and fabricated documents, and false declarations in important court documents.[250]I am satisfied that Mr Lodhia’s conduct of the proceedings was so unreasonable that it is appropriate and in accordance with the overriding objective that all of the Defendants’ costs are assessed on the indemnity basis. Urang’s set off application[251]I am told that proceedings were brought by Mr Lodhia against Urang for alleged breach of the GDPR (KB-2026-000549). Mr Lodhia obtained judgment in default of the defence being filed and, on 19 June 2026, Urang was ordered by Master Yoxall to pay the costs of the application to set it aside, including £840 on account. Urang applies to set this sum off against Mr Lodhia’s liability to pay it £3,600 on account of costs pursuant to my 18 May Order.[252]Although Mr Lazarev relied on CPR Rule 44.12, I am not sure that it applies. This Rule provides, so far as material, that:
“(1) Where a party entitled to costs is also liable to pay costs, the court may assess the costs which that party is liable to pay and either— (a) set off the amount assessed against the amount the party is entitled to be paid and direct that party to pay any balance;..” (a) set off the amount assessed against the amount the party is entitled to be paid and direct that party to pay any balance;..”
[253]Mr Lodhia plainly has no intention of paying any costs ordered against him. In the circumstances, it would seem unfair for Urang to be obliged, nevertheless, to pay him. However, it seems to me that under this Rule there would need to be an assessment of the costs which Urang is liable to pay in the other proceedings and the court would then be able to set Urang’s entitlement off against this sum. It would be for Master Yoxall to do this as it is his Order that the £840 be paid, and I am not seized of the claim which was before him and have little knowledge of it.[254]I therefore refuse this application. It seems to me that the appropriate course is for Urang to apply to Master Yoxall to vary his order or to make a further order. Totally without merit applications/whether Mr Lodhia should be subject to a civil restraint order[255]Pursuant to CPR Rule 3.11, Practice Direction 3C sets out the circumstances in which the court has a power to make a civil restraint order, the applicable procedure and the consequences of the different types of order. I have reminded myself of the guidance in the authorities including the judgment of Males LJ in Sartipi v Tigris Industries Inc [2019] EWCA Civ 225, [2019] 1 WLR 5892 at [25]-[37]. The key points for present purposes (again omitting his references to authority) are as follows:
“27. A claim or application is totally without merit if it is bound to fail in the sense that there is no rational basis on which it could succeed…... It need not be abusive, made in bad faith, or supported by false evidence or documents in order to be totally without merit, but if it is, that will reinforce the case for a civil restraint order. ….. “30. “Second, although at least three claims or applications are the minimum required for the making of an ECRO, the question remains whether the party concerned is acting "persistently". That will require an evaluation of the party's overall conduct. It may be easier to conclude that a party is persistently issuing claims or applications which are totally without merit if it seeks repeatedly to re-litigate issues which have been decided than if there are three or more unrelated applications many years apart. The latter situation would not necessarily constitute persistence.” ….. “37. … when considering whether to make a restraint order, the court is entitled to take into account any previous claims or applications which it concludes were totally without merit, and is not limited to claims or applications so certified at the time, albeit that in such cases the court will need to ensure that it knows sufficient about the previous claim or application in question…”
[256]The court is entitled to take into account totally without merit claims and applications on which an earlier civil restraint order was made: Society of Lloyds v Noel [2015] EWHC 734, [2015] 1 WLR 4393. As I have noted, in this case Mr Lodhia was subject to a GCRO from November 2022 to November 2024 based on 9 totally without merit applications in various sets of proceedings in at least 3 different courts.[257]In Chief Constable of Avon and Somerset v Gray [2019] EWCA Civ 1675 at [14] the Court of Appeal cited the following passage from the judgment of Stuart-Smith J with approval:
“In briefest outline, the question either on an original application for a GCRO or on an application for an extension is whether an order (or its extension) is necessary in order (a) to protect litigants from vexatious proceedings against them and/or (b) to protect the finite resources of the Court from vexatious waste. This question is to be answered having full regard to the impact of any proposed order upon the party to be restrained.”
[258]Applying these principles, for the reasons set out above I have concluded that the following applications by Mr Lodhia were totally without merit: a) His application dated 19 February 2026 to postpone the May hearing; b) His application dated 4 April 2026 to stay the proceedings; c) His application dated 22 April 2026 to postpone the May hearing; d) His application at the 6 May hearing for the hearing not to proceed on the grounds that his trustees in bankruptcy and/or his father had not been served with the proceedings; e) His 26 May 2026 application to me for permission to appeal to the Court of Appeal; f) His 25 June 2026 application for various matters; g) His 3 July 2026 application by way of an N244 application notice; h) His N600 application, on 3/10 July 2026 to commit Ms Yates for contempt of court.[259]Having regard to Mr Lodhia’s overall approach, I am also satisfied that his actions have had the necessary quality of persistence to warrant the making of a civil restraint order. Indeed, Mr Lodhia himself acknowledged during the July hearing that he had been persistent. I have considered whether it would be sufficient to make an Extended Civil Restraint Order (“ECRO”) but have concluded that such an order would not be sufficient or appropriate (see [4.1] of Practice Direction 3C). The evidence which I have seen suggests that Mr Lodhia is already litigating and/or threatening claims in relation to subject matter which goes wider than the scope of an ECRO, and against a number of parties other than the parties to these proceedings. In my judgment, a GCRO is appropriate in the present case and in my judgment it should be for a period of 3 years.[260]Mr Lodhia offered a confidential undertaking in lieu of a civil restraint order but I am afraid that this will not suffice. In my view it is very important that the restraints on Mr Lodhia’s litigation activity should be a matter of public record. A confidential undertaking would be very unlikely to be effective given the history which I have set out above.

Contempt of court

[261]In the light of my findings about the conduct of Mr Lodhia, I have concluded that this matter should be referred to the Attorney General’s Office for consideration of whether to proceed against him for contempt of court and/or to refer the matter to the police. Without in any way tying the hands of the Law Officers in relation to contempt of court, I note that I have found evidence which potentially amounts to the following criminal contempts: i) knowingly making of false statements in witness statements verified by a statement of truth (see CPR Rule 32.14); ii) knowingly making false statements in other court documents (statements of costs and certificates of service); iii) doctoring a court order (see e.g. Dryer v HSBC Bank plc [2014] EWHC 3949 (Ch)); and iv) falsifying documentary evidence (Cole v Carpenter [2020] EWHC 3155 (Ch)).[262]The Law Officers may also wish to consider proceedings for civil contempt, based on failure to comply with the orders of the court dated 29 April and 18 May 2026.

Order

his 24th statement which is dated 23 June 2026. The material parts of this do not take the matter further. Order: “Rradar would need to make an application if they wanted more information and given they have no prospect of recovery from me I do not suspect they will. You can simply state at the end, as [Mr Chiffers] has, you would be willing to consider any requests from the court”.