The Issue
Proceedings for contempt may be brought against a person who makes a false statement in a document verified by a statement of truth without an honest belief in its truth. The statement of truth exists to deter and address false verified statements in civil proceedings. Where verified pleadings contain statements that are later acknowledged to be inaccurate — or where contradictory verified positions are advanced across proceedings — those contradictions have procedural consequences that cannot simply be ignored.
The Law: How It Should Operate
CPR 32.14 — a person who makes a false statement in a document verified by a statement of truth without an honest belief in its truth may be proceeded against for contempt of court. The sanction is criminal in nature and the purpose is to ensure that parties do not lie in their pleadings. Henderson v Henderson — a party cannot without consequence advance inconsistent verified positions across proceedings.
How It Operated in Lawrence v HNW Lending Ltd
HNW's verified positions shifted materially across proceedings on the question of which instrument was operative, whether Ms Lawrence signed it, and the circumstances of execution. At RDC §64 HNW pleaded 'it is the Claimant's case that the Defendant did sign the Loan Agreement.' That position later became 'it is not HNW's case that Ms Lawrence signed the version containing the manuscript annotations.' The contradictions between verified positions were documented by the Applicants but not treated as undermining HNW's credibility or as a basis for any procedural consequence.
"The question is not whether one court reached one adverse result. It is that the same failure of protection recurred across courts, tribunals, administration, policing and oversight — making the pattern visible only because the case passed through so many forums."
— Open Letter to the Lord Chancellor, 15 May 2026