IN THE HIGH COURT OF JUSTICE
Claim No. -
King’s Bench Division
Administrative Court
In the matter of an application for Judicial Review
B E T W E E N:
The King on the Application of
(1) Ryan
(2) Mental Health Claimants
Claimants
-and-
(1) CPAG (proposed)
(2) EQUALITY AND HUMAN RIGHTS COMMISSION (proposed)
(3) GOOD LAW PROJECT LIMITED (proposed)
(4) MIND (proposed)
Interveners
-and-
(1) Secretary of State for Work and Pensions
(2) Cambridge City Council
Defendants
Statement of Facts and Grounds
Introductory
The claimant seeks the court's permission for judicial review regarding this and other interim orders on these matters and a related matter. In support are witness statements and exhibits.
The claimant challenges decisions and failures of the first defendant, the Secretary of State for Work and Pensions ("SSWP"), and the second defendant Cambridge City Council ("Cambridge", "landlord"). The claimant requires an injunction or other order to prevent the defendants from continuing to punish the claimant based on knowingly false information.
In other matters the claimant requires orders from the High Court to finalise his previous May 2025 claim, and to merge this with his county court claim from June 2025. That order is particularly time sensitive as the SSWP obtained a strike out hearing for 25 January 2026 to prevent the claimant from obtaining damages in the county court, based on the SSWP's deliberate misrepresentation to this court that email could not be used and that there was no PIP agreement.
This statement of facts and grounds addresses these issues:
A final order, costs and the joining of the previous matter and county court proceedings,
An injunctive order to prevent harassment from the SSWP employees.
An order preventing Cambridge from taking any steps in possession.
Transfer to the Upper Tribunal
The delay in pursuing the claim
The SSWP refusing reasonable adjustments by relying on a policy and the nature of an interview.
Cambridge's failure to take into account matters that they should when seeking possession of the claimant's home.
Orders
The claimant requests orders finalising the May 2025 High Court claim in his favour, because the claimant has been successful on the facts and law, that the SSWP can use email for identity in Universal Credit. On 25 June 2025 the claimant was identified by email through his landlord. Therefore, as the court agreed in the SSWP's favour that this was impossible, by quoting the law and the facts incorrectly, and deliberately knowing that they were false, the claimant would like the following orders for these reasons.
An order joining the High Court claim May 2025, and the County Court claim June 2025, and dismissing the SSWP strike out claim hearing 25 January 2026. This is because the purpose of the SSWP's strike out claim is to punish the claimant for successfully proving that email identification was possible and was done on 25 June 2025. Their claim has no basis in facts or law. It is another false and fraudulent claim like the 9 June 2025 submission to this court.
An injunctive order preventing Carla Buey and Ms Shah from managing the claimant's Universal Credit and other matters. This is because Ms Shah had made false claims in her summary grounds to the High Court dated 9 June 2025. In principle they claimed that email identity could not be done. The opposite is true in law and in fact (25 June 2025). But they continue to misrepresent to this court that email was used for identification, in their "updates" to the court letters dated 7 Jul 2025, and 3 Oct 2025. They knew at least by 25 June 2025 how the claimant was identified in his Universal Credit claim, by email, but they omitted it. On 7 July 2025 they knew as the claimant replied stating that the claim email was used to identify. And between then and 3 Oct 2025 the point of email identification was raised with his MP Daniel Zeichner, and they still omitted that email was used for identification on 25 June 2025, but this did not appear in any letters to the court.
Further reasons are based on the current reason for this new High Court Judicial Review for access to a paper-based assessment and the quashing of Cambridge's NOSP. Despite it being obvious that people misrepresenting the truth should not be permitted to deal with those they have been deliberately dishonest with, the SSWP still permitted Carla Buey and Ms Shah to administer to the claimant. Carla Buey herself is why the claimant could not use email. She said on 10, 11 June 2025 that this was not possible. Then on 25 June 2025 it was. She then was permitted despite it not being her position to, to further reject reasonable adjustments a second time on 5 Sept 2025 leading to this the second application to the High Court. Ms Shah on this latest matter of not permitting a paper-based interview provided fraudulent answers on 3 Dec 2025. Those are the reasons for the injunction against Ms Shah, Ms Dodson, and Carla Buey.
An order preventing Cambridge City Council from taking any steps in relation to possession. This order is needed because it was discovered that the reason for the NOSP was based on trying to harm the claimant. A recording made of the meeting on which the NOSP was based, is opposite of the report used to provide evidence for the NOSP. Namely that the claimant has no health or other circumstances preventing the rent being paid. The claimant sought an answer on 29 Oct 2025 for the omission, but was directed to an email address that has not been answered for 6 years. When this mistake in a way to provide reasons was put back to the decision maker to correct, he directed the claimant to speak to the legal team. The council will not be prejudiced by waiting to evict the claimant, as they have the exact same ways available to reclaim costs but better if the claimant retains his home and Universal Credit claims associated with it to pay those arrears. The NOSP is valid for 6 years from its making. Those are the reasons for an injunction against the council.
The claim for judicial review.
An order transferring part of the claim to the Upper Tribunal of the High Court. This order is necessary because this matter requires the expertise in the Social Security chamber for two reasons. First, to avoid false claims from the SSWP, like regulation 88 of PIP regulations prevents the defendant from doing something, when no such regulation exists. Additionally it prevents a claim that regulation 9 prevents paper-based assessments, when judgment in the chamber discussed paper-based assessments for PIP since 2017. Second, this case does not just rely on the truth, it relies on a careful interpretation of sections 23, 24 and 43 of the WRA 2012 being sufficiently wide to permit a paper-based assessment.
The claimant is being squeezed between two overbearing public bodies who both know that the maladministration they do is having an effect and is unlawful - material omissions, material delays, causing the claimant harm. This is designed to frustrate the purpose of the statutory objectives given to them to manage.
This is on top of both knowing that the claimant is disabled with health, capacity and trauma from repeat unfairness. Knowing this they do the same, and never apologise. In complaints both are repeatedly dishonest not just to the claimant but to other public bodies, and to the courts.
This additional claim is necessary because the defendants refuse to admit fault, but silently acquiesce and delay until they think nothing can be done to pursue an improper purpose.
The decisions
The First Defendant is the Secretary of State for Work and Pensions ("SSWP", "DWP") who has unlawfully refused the claimant permission to provide his information or evidence in connection with his UC claim on paper, as he does with PIP with the acceptance of the SSWP that meetings are distressing for the claimant. The decision is ongoing and is vitiated because it seeks to rely on policy instead of the sufficiently wide powers in section 23 of the Welfare Reform Act 2012, which is no less permissive than section 80 of the WRA for PIP that provides a paper-based assessment. This perversity of knowing meetings are harmful, and then claiming that a policy stops exercising discretion is a self-imposed fetter. It not only prevents the SSWP from entertaining the proposed flexibility in section 23, but also overrides other known and widely used relief like section 4, the discretion to not sign a claimant commitment at all, to relieve the claimant's extenuating circumstances. On this inclusion of irrelevant things, and the exclusion of relevant things, the same decision makers from the original claim, the claimant alleges deceit and conspiracy between Ms Shah, Ms Dodson and the decision maker Carla Buey, who have repeatedly misled courts about the SSWP's capabilities and legal obligations.
The Second Defendant Cambridge City Council ("the Council", "Cambridge") has unlawfully served a Notice of Seeking Possession (NOSP) dated 17 Sept 2025 after asking the first defendant on 4 September 2025 for a reasonable adjustment, noting the claimant's health, receiving a refusal 5 Sept 2025 and interviewing the claimant on 11 Sept 2025 at his home then seeking possession within 6 days. The decision is vitiated because the accuracy of Carla Buey's reply on 5 September 2025 was not material to their decision due to a policy of non-interference with the DWP. Additionally, when challenged about his omission of the claimant's disclosed health conditions, the decision maker Daniel Reynard directed the claimant to use the housing email. A seemingly harmless direction until the fact this email has never been answered to the claimant in 6 years.
The delay
The claimant asks for an extension in the time to pursue this application, if it is required. The claimant asserts that this application was done promptly once he held the late provision of reasons in his hand from the earlier decisions. See Trafford v Blackpool council and others regarding promptness, where it was held that waiting for the reasons completed the decisions, and the timer starts then. Further an extension was made on public interests of the claim being arguable and it being in the public interest to see that public bodies do not lie.
The SSWP decision was made on 5 Sept 2025, and is an ongoing refusal. They were asked on 10 Oct 2025, said they would provide in Nov 2025, then said they would provide on 2 Dec 2025. Then provided reasons on 3 Dec 2025, which is also another refusal. That deadline is 3 April 2026.
Cambridge's decision was made on or before the 17 Sept 2025 serving of the NOSP. The claimant asked for explanation on 23 Sept 2025; this was acknowledged, they spoke to legal and the decision maker, and made no effort to respond. A Judicial review PAP letter was sent on 2 Oct 2025, and was also discussed with legal, and answered as it did not require the response in the Judicial Review protocol. The response dated 3 Oct 2025 referred to the PAP letter as "comments made on the 2 Oct". However the key decision is that of 29 Oct 2025 when the decision maker revealed that malice was the reason for the serving of the NOSP as discussed above. The deadline is 29 January 2026.
Public interest in public bodies being fair. There is not exhaustive capacity for a decision to vitiate when it is discovered to be made in deceit. The defendants when confronted with deceit of their agents, some of which are solicitors, used their complaints systems in furtherance of the improper purpose.
Both used their legal powers to make getting a resolution more difficult. Both made strike out claims by further deceit. Switching the facts in the claim and pretending that they were defendants when it is not possible to change a cause of action, and Dolfus Miegg warned of the mischief of allowing non-defendants to meddle in cases without showing that interest or cause had passed to them. But to show interest the defendants' legal teams both dishonestly claim that they were the defendant and misrepresented the claimant's case to the courts. This exercise by the claimant also highlights a further perversity - they can respond promptly to claims not in their name, but cannot respond promptly or not at all to claims made in their own name.
Summary for grounds
SSWP
Improper purpose
Cambridge
Improper purpose.
Background
The claim
At all material time the claimant is a tenant is an individual and occupies the dwelling-house as his only or principal home in Cambridge since 19 August 2019 to present which the council is trying to seek possession for rent arrears.
The claimant successfully passed the introductory tenancy after a year. He has had not issues with rent or or warnings from the council. No anti social behaviour, no breaches in his tenancy for 6 years.
Prior to tenancy he was found to be homeless and provided a main housing duty due to his vulnerability. GT Steward was required to have his PHP reviewed. The housing team told the claimant there no social housing in Cambridge, and was given a prefilled housing plan. Later, against the housing team, he then required a discrimination charity to move on his disability bathroom after 5 years and an OT report. The bathroom is in disrepair, amongst other things, the bathroom tiles are covered in glue and peeling having been installed that way. In this time approx 6 years plus the Housing Officer email has never returned the claimants emails. Complaints have to be made to have issues addressed. The complaints are deleted or not answered.
At all material time the claimant satisfies the conditions to have a Universal Credit award. The SSWP knows the claimant health and conditions, including permitting the claimant to have paper based assessment and use email to communicate.
The claimant had a PIP assessment in Nov 2019 ATOS assessment - which the claimant took his partner and he secretly recorded the 1hour interview. He took his PIP claim and evidence in a folder and tried to read from it to answer the questions. A dental nurse was provided to assess him for cognitive and mental health problems. After an hour the dental nurse said she could not find his evidence. She asked him to leave and find the evidence with the DWP. The DWP records made by the dental Nurse state that the claimant walked out, they also report that she locked the claim so that it could only be seen if it was directly searched for. The MP and CPAG was used to facilitate a paper based assessment.
Facts
PIP
There was an agreement between the claimant and the DWP for non-live assessments. The offer 20 July 2020 the claimant sent a 40 page letter before action to DWP PIP asking for a paper-based assessment and email. And the agreement 22 July 2020 - 2 questions for PIP sent to claimant from DWP PIP. PIP was awarded 2019 to 2025.
The DWP broke that PIP agreement in May 2025 by sending the claimant to phone calls. In GDPR reports the reason for not using paper-based assessment was not based on lack of evidence. It was the "156" pages being over the "TACT" limit time for an assessment.
UC
The claimant asked for reasonable adjustments with UC that he had with PIP, from his 8 April 2025 managed migration to UC. The SSWP UC agents said that they had no policy for email.
The claimant applied to enforce the PIP agreement and the duty to make reasonable adjustments for both UC and PIP on 6 May 2025 by High Court Judicial Review. The PIP agreement emails were in the bundle and referred to directly.
The SSWP in their claim made false claims of fact and law in their summary grounds, High Court dated 9 June 2025. SSWP Ms Shah and Ms Dodson claimed that the SSWP cannot lawfully use email in PIP and UC. And claimed that there was no PIP agreement.
The UC staff member Carla Buey falsely claimed that email and landlord identification could not be done in journal texts 10 and 11 June 2025. She did this after she was shown the DWP policy for landlord identification of a claimant on the 10th. She then on the 11th June 2025 made a further false statement confirming that the policy was real, but is applied after the postal consent was sent.
The claimant sued the UC staff separate from the SSWP in an MCOL claim, as they appeared to be not following the DWP guidance shown to them on the 6, 10, and 11 June 2025. He emailed the notice to the first defendant and the second defendant on 20 June 2025.
As a result of this claim the High Court fraud of the SSWP and the UC staff was unravelled when the UC staff contacted the second defendant to identify the claimant by email on 25 June 2025.
The SSWP made another fraudulent claim to strike out the claimant's MCOL dated 20, 23 June 2025. Ms Haq, claimed amongst other things that government employees are immune from claims, and claimed from false facts that the claimant's statement of case showed a different cause of action against the SSWP not the UC staff.
The SSWP still tried to maintain the frau no email and no PIP agreement to the High Court with 7 July and 3 Oct 2025, by omitting how the claimant was identified and inventing that the claimant was. Ms Shah and Ms Dodson knew before these updates that what they were fraudulently claiming was deliberate.
The SSWP did these things to harm the claimant.
Council.
The council used false information from a report dated 11 Sept 2025 to serve a NOSP seeking possession dated 17 Sept 2025.
The majority of or all of the council's representations to the claimant or others were to secure the NOSP or disguise that the NOSP was based on fraud and/or the malice of the housing officer team from 2019 for the purpose of continuing to harm the claimant by deliberately not providing a service.
Further details is provided in the particulars of improper purpose below, and the witness statements.
Law
SSWP
Work Reform Act 2012
s4 in extenuating circumstances the claimant does not need to satisfy the basic or financial conditions for an award of universal credit. The claimant commitment may be signed by the SSWP on the claimant's behalf.
s23, 24, 43 of SSWP can ask the UC claimant to attend or not, or to report, or not. Attendance is not required.
s80 SSWP can ask the PIP claimant to attend or not, or to report, or not. Attendance is not required.
C and P regs 2013
37 of the SSWP can request landlord provide any information about a tenant.
Sch 2, 4, 5, the SSWP can use any form electronic communication or storage if agreed.
In PHC v SSWP:
Identity is the assigning of a NINO to a UC claim. If they do not have one, one is provided. This is based on the balance of probability. It must be asked what information the SSWP had before assigning a NINO.
UC representative policy
The landlord or other may be the claimants representative
UC identity policy
The claimant may be identified with biometric data provided by their landlord or or themselves.
PIP policy
Those who find face-to-face appointments stressful have a paper-based assessment.
Gainfully self-employment policy.
The appointment must be live, claimant must sign the claimant commitment at the interview.
Cambridge CC
s84, and sch 2 of the Housing Act 1985 purpose of the act is to be fair.
A series of case show the purpose of the social housing is to take into account reasonability, health, pending benefits, if the claimant has been asked to do something that they cannot do, Woodspring v Taylor, Connock, Nurse.
The social landlord possession protocol which: Invites the social landlord to ignore the statutory obligations or to do something only if they are "aware".
Income management and arrears policy: misdirects the reader to ignore the protocol until the last minute.; misdirects the reader to ignore the HRA, Care Act, and other statutory obligations.; team are solely required to help vulnerable persons without any direction to social service, advocacy or a responsible adult; The Warrant checklist requires the director to know if the tenant has a health condition; states no duty to be fair to the tenant.
Complaints policy: Only legal complaints that are disrepair complaint can be put into the complaints system. The ombudsman will not accept legal complaints.
"our vision:
‘One Cambridge, Fair for All’ Residents enjoy a high quality of life and exemplar public services; Cambridge is a place of high employment where everyone has a warm, safe, and affordable home, and beautiful open spaces to enjoy.; Communities are thriving and empowered, supported by well-run public services, and drawing on shared prosperity with greater equality in health and educational outcomes.
"Democratic accountability is genuine and accessible: Residents actively participate in democratic life and transparent decisions are made by and for the people of Cambridge.; There is genuine partnership between academic, business, and civic communities to enhance residents’ prosperity; Local control, devolution, and community empowerment are championed through transparent and simplified local government."
Our equality and diversity policies and plans: "We are committed to challenging discrimination and promoting equality of opportunity in all aspects of our work."
Several principles of statutory interpretation:
1. Where a word is used more than once in the same statute, it will be taken to have the same meaning throughout. 2. A statute should not be interpreted to produce an absurd result, with absurdity given a wide meaning to include impossibility, impracticability and futility. 3. Subordinate legislation may be persuasive authority as to the meaning of the primary statute. 4. Statutory guidance may have persuasive authority but has no particular legal status. 5. In some cases, settled practice may be relied on as an aid to interpretation.
The Court of Appeal reaffirmed the established principles for granting interim relief in public law cases: the need to identify a serious issue to be tried, the adequacy of damages if an interim injunction were refused, and the balance of convenience, with particular weight given to the public interest and national security considerations.
Public interest and improper purpose for amenability: "Solicitors...owe duties to the courts third parties and to the public interest."
Wheeler v Leicester City Council [1985] AC 1054: Established that public bodies must act fairly and cannot misuse statutory powers to punish entities without just cause.
R v London Borough of Ealing ex parte Times Newspapers Limited [1987] IRLR 129: Highlighted that decisions motivated by irrelevant considerations, such as supporting strike actions, are unlawful.
R v Derbyshire County Council ex parte Times Supplements Limited (1990) 3 Admin LR 241: Reinforced that actions taken in bad faith or for improper purposes must be quashed.
"I fail to see how it could ever be said that a decision of a local authority taken in bad faith or otherwise for improper purpose can have arisen from the exercise of power for the public good. If, as Mr Lester suggested, the removal of advertising from the TES to the Guardian only arose from a vendetta by the county council against the Times Newspapers Ltd I would regard this court as under a direct positive duty in the public interest to strike down such a decision."
R v Lewisham LB ex parte Shell UK Ltd [1995] 1 All ER 938: Demonstrated that mixing improper motives with lawful purposes vitiates the entire decision.
R v Somerset County Council ex parte Fewings [1995] 1 All ER 513: Emphasized the necessity for public bodies to consider all relevant factors and not fetter their discretion.
Mercury Energy Ltd v Electricity Corporation of New Zealand Ltd [1994] 1 WLR 521: Asserted that judicial review of commercial contract decisions requires evidence of fraud, corruption, or bad faith.
Molinaro v Kensington & Chelsea BC [2001] EWHC Admin 896: Supported the notion that exercising statutory functions with public law elements can render decisions amenable to judicial review.
"67. But public bodies are different to private bodies in a major respect. Their powers are given to them to be exercised in the public interest, and the public has an interest in ensuring that the powers are not abused. I see no reason in logical principle why the power to contract should be treated differently to any other power. It is one that increasingly enables a public body very significantly to affect the lives of individuals, commercial organisations and their employees."
Cookson & Clegg v Ministry of Defence [2005] EWCA Civ 811: Clarified that public law challenges are permissible in cases of bribery, corruption, or ultra vires policies.
Hampshire County Council v Supportways [2006] EWCA Civ 1035: Highlighted the limitations of transforming private law claims into public law claims solely based on the public body's institutional nature.
Bevan & Clarke LLP & others v Neath Port Talbot BC [2012] EWHC 236 (Admin): Expanded on the grounds of abuse of power to include failure to account for relevant considerations.
Trafford v. Blackpool Borough Council ([2014] PTSR 989) is a significant judgment delivered by the England and Wales High Court (Administrative Court)
Particulars of improper purpose
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