LTM -v- Solicitors Regulation Authority (anonymity order)

Administrative CourtHigh CourtKing's Bench DivisionAnonymity Order

Case number: AC-2026-LON-001993

In the High Court of Justice
King’s Bench Division
Administrative Court

In the matter of an application for judicial review

11 August 2026

Before:

Duncan Atkinson KC,
sitting as a Deputy High Court Judge

Between:

The King
on the application of
LTM
(Claimant)

-v-

Solicitors Regulation Authority
(Defendant)


Order

Notification of the Judge’s Decision (CPR 54.11, 54.12)

Following consideration of the documents lodged by the Claimant, the Defendant’s Summary Grounds of Defence

ORDER BY DUNCAN ATKINSON KC, sitting as a Deputy High Court Judge

  1. Anonymity:

(a) Pursuant to CPR 39.2(4) and/or the Court’s inherent jurisdiction and/or s. 6 of the Human Rights Act 1998:

(i) the Claimant’s name is to be withheld from the public and must not be disclosed in any proceedings in public; and

(ii) the Claimant is to be referred to orally and in writing as LTM.

(b) Pursuant to s. 11 of the Contempt of Court Act 1981, there must be no publication of the identity of the Claimant or of any matter likely to lead to the identification of the Claimant in any report of, or otherwise in connection with, these proceedings.

(c) Pursuant to CPR 5.4C(4):

(i) the parties must within 7 days file a redacted copy of any statement of case filed, omitting the name, address and any other information likely to lead to the identification of the Claimant;

(ii) if any statement of case subsequently filed includes information likely to lead to the identification of the Claimant, a redacted copy omitting that information must be filed at the same time;

(iii) unless the Court grants permission under CPR 5.4C(6), no non-party many obtain a copy of any unredacted statement of case.

(d) Any person wishing to vary or discharge this Order must make an application, served on each party.

  1. Permission: Permission to apply for judicial review is refused.
  2. Costs: The Claimant must pay the Defendant’s costs of preparing the Acknowledgement of Service and Summary Grounds of Defence, summarily assessed in the sum of £2363.20.
  3. Further provision as to costs:

(a) Where the Claimant does not make a valid request for reconsideration of the decision to refuse permission to apply for judicial review (see notes below):

(i) Within 24 days of the date of this Order, the Claimant may file and serve a notice of objection (maximum 3 pages) showing why the order in paragraph 2 should not be made. The notice should include any objections to the principle that costs should be paid and/or as to the amount assessed.

(ii) If the Claimant does not file and serve a notice of objection within that period, paragraph 2 is a final order and the Claimant must pay the sum specified within 14 days of the date of this Order (in accordance with CPR 44.7(1)(a)).

(iii) If the Claimant files and serves a notice of objection in accordance with (i) above:

  • the other party may, within 14 days after the date on which the notice is served, file and serve submissions in response (maximum 3 pages);
  • if the other party files and serves on the Claimant submissions in response, the Claimant may, within 14 days after the date on which the other party’s submissions in response are served, file and serve reply submissions (maximum 3 pages);
  • the Court will determine what costs order to make on the papers;
  • any costs ordered must be paid within 24 days of the date of the Court’s order (in accordance with CPR 44.7(1)(a)), unless the Court specifies another date.

(b) Where the Claimant makes a valid request for reconsideration (see notes below):

(i) Paragraph 2 does not become final as respects the costs payable to any party unless, insofar as it relates to that party:

  • the Claimant withdraws the application for permission; or
  • permission to apply for judicial review is refused on all grounds after a hearing.

(ii) If the Claimant wishes to contend that the order in paragraph 2 should not be made even if permission is refused on all grounds, the Claimant must within 14 days after the date of this Order file and serve (together with the request for reconsideration) a notice of objection (maximum 3 pages). The notice should include any objections to the principle that costs should be paid and/or as to the amount assessed.

(iii) If the Claimant files and serves a notice of objection in accordance with (ii) above:

  • the other party may, within 7 days after the date on which the notice is served, file and serve submissions in response (maximum 3 pages);
  • if the other party files and serves on the Claimant submissions in response, the Claimant may, within 14 days after the date on which those submissions are served, file and serve reply submissions (maximum 3 pages);
  • the Court will determine what costs order to make at or after the permission hearing;
  • any costs ordered must be paid within 24 days of the date of the Court’s order (in accordance with CPR 44.7(1)(a)), unless the Court specifies another date.

5. Renewal directions: Where the Claimant makes a valid request for reconsideration (see notes below), the following directions apply:

    (a) The permission hearing is to be listed with a time estimate of 1 hour, including submissions by the parties and an oral judgment by the judge. If the Claimant considers that more time should be allowed, the time estimate must be included with the request for reconsideration of permission.

    (b) Within 28 days of the service of this Order, the Claimant must file and serve an electronic copy of the Permission Hearing Bundle, prepared in accordance with the guidance on the Administrative Court website and containing the following documents:

    (i) the Claim Form, Statement of Facts and Grounds and any evidence or other documents filed with the Claim Form;

    (ii) any Acknowledgment of Service, Summary Grounds of Defence and any accompanying documents served by any Defendant and/or Interested Party;

    (iii) any Reply or other document served by any party to the proceedings at the paper permission stage;

    (iv) this Order;

    (v) the renewed application for permission to apply for judicial review (on Form 86B);

    (vi) any other document the Court would be likely to consider material to its decision on permission to apply for judicial review.

    (c) If the Claimant fails to comply with sub-paragraph (b), permission will be determined on the basis of the renewal notice and the documents before the Court at the paper stage, unless at the hearing the Court otherwise directs.

    (d) At least 7 days before the date listed for the hearing, the Claimant must file and serve:

    (i) a skeleton argument, maximum 10 pages;

    (ii) an electronic bundle containing any authorities which the Court needs to read at the hearing (the Authorities Bundle: see para. 22.1.2 of the Administrative Court Judicial Review Guide); and

    (iii) if requested by the Court, a hard copy version of the Permission Hearing Bundle and Authorities Bundles.

    (e) At least 7 days before the date listed for the hearing, any party other than the Claimant intending to participate in the hearing must file and serve any skeleton argument, maximum 10 pages.

    (f) If a party fails to comply with sub-paragraph (b), (d) and/or (e), the Court may have regard to the failure when considering any question about costs at the hearing.

    1. Reasonable adjustments: The Court notes that the Claimant is disabled, unrepresented and communicating in other than his first language. The timetable in relation to costs and renewal have been varied to make reasonable adjustments in this light. The Claimant may undertake communication in advance of any hearing electronically. Whether the Claimant may rely on written rather than oral submissions at the oral hearing will be a matter for the Judge dealing any such hearing.

    REASONS

    (1) Anonymity: The claim relies on personal medical information in which the Claimant has a reasonable expectation of privacy. There are accordingly compelling reasons for the limited derogations from the principle of open justice in paragraph 1.

    (2) Reasonable adjustments: The material provided by the Claiamnt demonstrates the need for some reasonable adjustments for the Claimant, given that he is disabled, unrepresented and communicating in other than his first language. Not all of the measures he requests are justified on the face of the materials on which he relies. It is inconsistent with the extension of time periods to assist the Claimant to also order expedition, and I have not done so. No case for one judge dealing with all hearings has been made out.

    (3) Permission: The Claimant seeks to challenge the decision of the Defndant on 12 September 2025. not to investigate the conduct of Caroline Acton on Worknest Ltd. That decision was confirmed on 30 December 2026. Whilst the present application is out of time, by reference to CPR 54.5, making reasonable adjustments for the Claimant, I have considered the matter on its merits, rather than just by reference to the delay to the application, which would otherwise have justified the refusal of permission.

    (4) The Claimant seeks to advance 15 grounds. They are not reasonably arguable given the following:

    (a) It was recognised in R (Panton) v Securities and Futures Authority (20/6/1994, unreported) that the Court should be reluctant to interfere with the decisions of a regulatory body such as the Defendant, ands should only do so in very clear cases. It is not reasonably arguable that this is such a very clear case. Indeed, if anything, it is clearly not.

    (b) Under the SRA Regulatory and Disciplinary Rules (‘the Rules’), the Defendant had a broad discretion as to which cases, and which types of cases, it should accept. It is a matter for the Defendant to interpret the Rules, and no public law error is arguably revealed by the Claimant’s case, or engaged by his grounds.

    (c) The Defendant’s decisions were in accordance with the Rules, and the Assessment Threshold Test therein. The Defendant is required to act in accordance with the public interest, and its approach is not inconsistent with this.

    (5) Against that background it is not necessary to provide a separate reasoning for the refusal of permission for each of the Claimants grounds, some at least of which are unparticularised and/or duplicative. In summary, there is no reasonable argument that the decision involved a failure to engage with or to consider the relevant material and the Claimant’s allegations, a failure sufficiently to explain its decision, a failure to keep the Claimant informed as required, a failure to apply the correct test or to apply the wrong one, and/or a failure to comply with its statutory or regulatory duties. The decision cannot reasonably be argued to be in breach of its rules, the Equality Act 2010 or the ECHR. As the Defendant rightly observes, the Claimant’s grounds reveal disagreement with the decision, rather than exposing an arguable basis in public law to challenge it. Permission is therefore refused on all the grounds. None is arguable.

    Signed: Duncan Atkinson KC

    Date: 11/8/2026