IN THE [Insert Higher Court Name]
BETWEEN:
[Appellant Name]
Appellant
[Respondent: e.g., Chief Constable / Court Service / Enforcement Authority]
Respondent
🔑 OUTLINE OF GROUNDS
1. Contradictory Judicial Orders – Legal Error
- Order dated 21 July 2025 directly contradicts earlier relief granted on 30 June 2025 under the Police (Property) Act 1897.
- Breach of legal certainty and equity:
“An order which contradicts a former without revocation is void in equity.”
2. Procedural Irregularity and Lack of Reasoning
- No substantive rationale was provided for denial.
- Breaches obligation per English v Emery Reimbold [2002] EWCA Civ 605.
- Triggers appealable irregularity under CPR 52.21(3)(b) and Article 6 ECHR (Kudla v Poland [2000] ECHR 512).
3. Jurisdictional Collapse and Absence of Authority
- If the second judge disregarded the standing order without formal revocation, jurisdiction may have been exceeded:
“Once jurisdiction is lost, everything thereafter is void.”
4. Psychological Impact and Procedural Abuse
- Evidence submitted (Log #641) demonstrates psychological impairment due to procedural contradictions.
- Invokes equitable protection:
“Equity abhors a forfeiture.” and “The law respects form less than substance.”
5. Failure to Consider Relevant Precedent
- R (Cart) v Upper Tribunal [2011] UKSC 28 affirms need for procedural and interpretive coherence.