Important notice: All content on this page is drawn exclusively from filed court documents, filed witness statements, and skeleton arguments in proceedings LC-2024-134, LC-2024-149, LC-2024-150, LC-2024-706 and related appeals. These are the Applicants' allegations. They do not constitute findings of misconduct or judicial misbehaviour. Judge Sara Hargreaves is entitled to the presumption of having acted in good faith. The purpose of publication is to support open justice: the principle that judicial conduct in proceedings affecting property rights should be visible and capable of scrutiny.
Background: What the FTT Was Asked to Decide
The Applicants brought objections to HM Land Registry applications to register legal charges and transfers over multiple properties including Venus Mews and 29 Watson Place. The objections raised, in express terms: forgery; composite deed (signature-page transplantation); escrow non-delivery; void instrument; pending High Court proceedings on the same instrument; and forensic expert evidence of document manipulation.
The Applicants allege that Judge Hargreaves did not apply that guidance. Instead — on the Applicants' filed case — the FTT used the Rule 9 disposal mechanism to close the objections as having "no reasonable prospect of success," directed HM Land Registry to proceed "as if no objection had been made," ordered immediate registrations before any appeal could be brought, repeated that approach when challenged, and then debarred the Applicant without giving reasons. The Upper Tribunal subsequently stayed the proceedings — which the Applicants say confirms the issues raised were not plainly hopeless.
The direction of every departure
In each of the nine departures below, the safeguard that was removed was one that could have protected the Applicant's property rights or allowed her fraud and escrow case to be tested. No departure assisted the Applicant. No departure required HNW or the registered proprietors to prove the instrument's provenance, delivery, or escrow release. The consistent direction is what the Applicants say transforms nine individual errors into a structural pattern.
Opinions Without Adjudication — The Blocked Route to Truth
The judge declined to fact-find. She did not try the fraud. She did not test the escrow. She did not order the originals. But she did form and express negative characterisations of Ms Lawrence's case — characterisations that are alleged to have been based solely on the judge's own reading of disputed documents, without disclosure, without cross-examination, and without the forensic testing that would have been the only legitimate basis for those conclusions.
The Applicants allege a specific and serious procedural inversion: Judge Hargreaves refused to conduct the fact-finding that would have justified conclusions about Ms Lawrence's case — but made negative characterisations of that case anyway. The objections were labelled "hopeless," the issues characterised as a "waste of time," and the allegations treated as having "no substantial basis" — none of which followed from any examination of the forensic evidence, the escrow chronology, or the execution record. Those characterisations were therefore not judicial findings. They were opinions expressed from a position that had closed the route to the evidence on which any legitimate opinion would have to rest.
The legal principle is foundational: a judicial conclusion about a party's case requires that the party's evidence has been tested and the opposing evidence has been examined. A conclusion reached before that process — or in place of it — is not an adjudication. It is an assertion made from a position of procedural authority. When that assertion negatively characterises a BAME litigant's fraud allegations while simultaneously refusing to examine the forensic evidence that supports them, the Applicants say the result is something more corrosive than error: it is the use of judicial authority to disparage a case that the court has declined to hear.
The stamped Setfords cover letter establishing that charges were transmitted before the £1.6 million terms existed was before the tribunal. The Keith Borer forensic report — with its conclusion of "conclusive evidence" of signature-page transplantation — was before the tribunal. The objective chronological evidence that Ms Lawrence was abroad when the deed was said to be executed was before the tribunal. None of it was tested against originals. None of it produced a disclosure order. But all of it was, on the Applicants' case, characterised as insufficient — an assessment made without the examination that alone could justify it.
The full schedule of negative statements made by Judge Hargreaves — including the specific characterisations alleged to have been made without prior fact-finding and the procedural moment at which each was expressed — is documented in the filed record and available for scrutiny below. Open justice requires that judicial statements of this kind, made in proceedings affecting property rights, be visible. The characterisations are not protected from scrutiny by the authority of the person who expressed them. They are examined by asking a single question: what was the evidential basis for this conclusion at the point it was made?
↓ Download — Hargreaves Negative Statements (PDF)Registrations allowed while live fraud allegations remained undetermined
The Applicants had expressly raised, in their objection grounds and in the FTT statement of case, that the legal charges were void on grounds including forgery, composite deed, and escrow non-delivery. The forgery ground was specifically articulated as: "the signature to the Legal Charge is a forgery and as such the lender's power of sale has not arisen." The FTT was therefore on notice that the instruments whose registration was being sought were challenged as void — not merely voidable, not subject to a technical defence, but void from the outset.
The Applicants allege that Judge Hargreaves allowed the registration applications to proceed — and directed HMLR to proceed "as if no objection had been made" — without determining those allegations. By directing registration while the fraud allegations remained live, the judge embedded instruments the Applicants said were void into the register, hardening the very position the Applicants were in the process of challenging.
Rule 9 disposal used to close fraud and escrow issues without substantive engagement
Rule 9 of the Tribunal Procedure (First-tier Tribunal) (Property Chamber) Rules 2013 permits the tribunal to strike out a party's case if it has "no reasonable prospect of success." The Applicants allege that Judge Hargreaves applied Rule 9 to close the objections — using characterisations including "hopeless," "no substantial issues," and "waste of time" — without engaging with the substance of the fraud and escrow allegations, the expert material, or the objective indicators (including the Applicant being abroad when the deed was said to be signed).
The Rule 9 test requires a genuine assessment of whether there is a realistic prospect of success — which in a fraud case necessarily involves engaging with the evidence rather than dismissing it by label. The Applicants say the characterisations were substituted for that analysis. A properly particularised forgery allegation supported by forensic expert evidence and objective chronological indicators is not "hopeless" for the purposes of Rule 9. It requires a hearing, disclosure, and fact-finding.
Escrow delivery issue not investigated — escrow argument treated as resolved without a finding
The Applicants' statement of case expressly raised escrow non-delivery: the legal charges were transmitted to solicitors before the £1.6 million terms were created (stamped Setfords cover letter, 14–15 November 2018); the manuscript amendments creating those terms were made on 30 November 2018; no act of unconditional release for the materially different terms was identified; and the Applicant was abroad when the amended deed was allegedly executed. The objector's grounds as recorded by HMLR in the case summary for 29 Watson Place noted the charge "under which the Transfer is made is void" and that the Applicant "claims that she did not execute the Legal Charge."
A deed held in escrow for one set of terms is not automatically released for materially different terms. The question of what act released the charges — and whether that release was lawful for the £1.6 million structure — required fact-finding. The Applicants allege the FTT treated the escrow issue as if it had been resolved or was not substantial, without identifying where or by whom it had been determined.
Forensic expert evidence disregarded without engagement — no originals ordered
Keith Borer Consultants (Ref: 95634-KC-141125) provided forensic evidence that the signature pages of the two HNW loan agreements are "both different-generation copies of the same 'master' version" — which is physically impossible if both signatures were made on separate occasions. This is not a disputed interpretation; it is forensic evidence characterised by the expert as "conclusive."
The Applicants allege that Judge Hargreaves proceeded to dispose of the objections without ordering disclosure of the original documents, without requiring HNW to produce originals for forensic inspection, and without engaging with the expert finding. In any document-tampering case where independent expert evidence establishes a prima facie case of composite construction, the correct procedural response is to order production of originals and fix a hearing. Disposal without that step means the expert evidence was disregarded rather than answered.
Immediate registration ordered before the Applicant could appeal — appeal rights extinguished in advance
Having used Rule 9 to close the objections, the Applicants allege that Judge Hargreaves directed HMLR to proceed "as if no objection had been made" — and that registrations were completed before the Applicant had any realistic opportunity to apply for a stay pending appeal. HMLR then pre-empted a further decision and registered a fourth disputed title without separate tribunal authority. The Upper Tribunal subsequently stayed the proceedings — which the Applicants say is itself recognition that the issues raised were not exhausted.
The practical effect was that the register was altered on the basis of instruments the Applicants were challenging as void, before the challenge could be tested, appealed, or stayed. Once registered, the new proprietors began to exert ownership, causing ongoing damage. The very evidence being assembled to challenge the registrations was disrupted by the consequences of the registrations themselves.
Error repeated when challenged rather than corrected — same departure applied twice
The Applicants allege that when they raised the procedural error with the FTT — pointing out that live fraud and escrow allegations had been closed without determination — Judge Hargreaves did not correct the approach. Instead, the same method was applied to a further objection: fraud and delivery issues again characterised as having no reasonable prospect, and registration again directed. The Applicants say that repeating the same departure after it has been specifically challenged removes the possibility of characterising the first instance as inadvertent error.
The Upper Tribunal's subsequent stay of proceedings — acknowledging that the issues were live — is the institutional recognition that the repeated approach required review. But the repetition meant that by the time the Upper Tribunal intervened, multiple registrations had been completed and multiple properties had changed hands on the basis of instruments whose provenance had never been judicially determined.
Overriding interest — actual occupation of BAME residential occupiers not investigated
The properties affected included residential properties at Venus Mews CR4 and 29 Watson Place, which the Applicants say were in actual occupation. LRA 2002 Schedule 3 paragraph 2 confers an overriding interest on persons in actual occupation — meaning that their rights bind a purchaser or registered proprietor regardless of registration. The effect is that registration does not extinguish an overriding interest. If the FTT was aware of actual occupation, it was required to consider whether registration would bind or be subject to the occupiers' interests before directing that registrations proceed.
The Applicants allege the FTT did not investigate actual occupation, did not consider whether occupiers' interests would override the registered dispositions, and did not address whether the persons who were later removed by forced entry had legal protections that preceded and survived registration. This failure compounded the harm because the registrations themselves became the platform for the evictions that followed.
Debarment without reasons — despite repeated specific requests
When the Applicant challenged the FTT's approach, the Applicants allege that Judge Hargreaves debarred the Applicant from the proceedings without providing any reasons — and that this occurred despite the Applicant specifically and repeatedly requesting the basis for the debarment decision. Debarment is one of the most serious procedural sanctions available in tribunal proceedings. It extinguishes the debarred party's ability to participate in the substantive hearing entirely. A debarment without reasons in those circumstances leaves the debarred party unable to understand the basis of the decision, unable to address the reason in any future application, and unable to assess whether an appeal has merit.
The Applicants characterise this as a culminating departure: having used Rule 9 to close the fraud issues, directed immediate registration, repeated the approach when challenged, and ignored actual occupation — the FTT then removed the Applicant's participation rights without explanation. At that point, the Applicant had no fraud trial, no escrow trial, no disclosure, no expert testing, no reasons for disposal, and no reasons for debarment.
Equal Treatment Bench Book provisions not applied — BAME LIP treated as procedurally equivalent to represented corporate lender
The Applicant was a BAME litigant in person. HNW Lending Ltd was a corporate lender represented by specialist solicitors throughout. The Equal Treatment Bench Book, which applies to all courts and tribunals in England and Wales, requires that a litigant in person is not treated as procedurally equivalent to a legally represented party. Where a LIP has failed to articulate a point with technical precision, that failure carries less weight than it would for a represented party. The FTT is required to take reasonable steps to assist a LIP in understanding what is required and to ensure their participation is effective.
The Applicants allege that the FTT applied the Rule 9 "no reasonable prospect" test against a BAME LIP in a complex fraud, forgery and escrow case without any adjustment for the inequality of arms; treated the failure to fully particularise as a reason to close rather than as something to be assisted; and — when the LIP raised the procedural objection — responded with debarment rather than explanation. The consistent operation of every departure against the LIP and in favour of the represented corporate lender is the equality dimension the FTT guidance requires to be examined.
The direction question. Every one of the nine departures above operated against the BAME Applicant and in favour of the corporate lender. There is no documented departure that required HNW to prove provenance, escrow release, or execution. There is no departure that gave the Applicant additional time, assistance, or disclosure. There is no departure that recognised the forensic expert evidence as requiring engagement.
The Applicants do not allege that Judge Hargreaves acted with conscious racial motive. The question the Macpherson framework requires to be asked is objective: how is it possible that every safeguard designed to protect the BAME Applicant's property and participation rights was withheld, across nine documented instances, without any corrective movement in the other direction? That is the question open justice requires to be answered.
The institutional loop. The fraud and escrow issues were raised before the FTT and not determined. The Court of Appeal later proceeded on the premise that had escrow truly been raised before the FTT, the FTT would have determined it. The Applicants' case is that it was raised and not determined — and that this closed loop, where issues are raised but treated as determined elsewhere, is the structural mechanism by which lawful adjudication is replaced with procedural administration of a predetermined outcome.
The Rule-of-Law Question
Can a tribunal declare fraud "hopeless" without originals, disclosure, expert engagement, cross-examination, or a hearing — and call that adjudication? Can debarment without reasons satisfy the duty in English v Emery Reimbold? Can directions to register void instruments before appeal satisfy Article 6 and A1P1? Can these nine departures, all in the same direction, be explained as ordinary case management of a BAME LIP's property rights?
If the answer to any of those questions troubles you, this case needs scrutiny. Not to relitigate it — to ask whether the process it followed met the standard the rule of law requires. And to ask one further question: on what evidential basis did the judge characterise Ms Lawrence's fraud case as hopeless — at a point when the forensic evidence had not been examined, the originals had not been ordered, and the disclosure route had been closed?
Filed record — negative statements
The full schedule of negative characterisations alleged to have been made without prior fact-finding — with the procedural moment at which each was expressed — is publicly available for scrutiny.
↓ Download the negative statements schedule (PDF)