Legal Watch:Professional IndemnityApril 2014 – Issue: 001

In This Issue:

• Honesty of solicitors not enough to invoke

court’s mercy

• A bird in the hand is probably worth two in the

bush for FOS complainants

• Calderbank offer trumps part 36 in a

construction dispute

• Surveyors escape liability for injured pedestrians

The Court of Appeal (CA) has overturned a ruling which

excused from liability an innocent law firm swindled into

releasing £150,000 of mortgage funds.

In Santander UK Plc v RA Legal Solicitors, the court ruled that

the failings of RA Legal in departing from conveyancing best

practice were unreasonable and not deserving of the court’s

mercy. The case concerns section 61 of the Trustee Act 1925,

which gives the court power to absolve a trustee from personal

liability for breach of trust if he has acted “honestly and

reasonably” and “ought fairly to be excused” for the breach

of trust. Section 61 has become the principal mechanism by

which the law tempers a trustee’s otherwise strict liability in

these circumstances.

BackgroundIn May 2009 Santander UK Plc (formerly Abbey National)

agreed to lend £150,000 to Mr Vadika for the purchase of a

residential property in London. The now defunct RA Legal was

instructed to act for them both.

RA Legal (R) understood that Sovereign Chambers LLP

acted for the vendor. Although a firm of solicitors in good

standing with the Law Society, the person purporting to be

the conveyancer at Sovereign, was in fact a fraudster. The

vendor had never retained Sovereign to act on her behalf, nor

agreed to sell the property to Mr Vadika. The transaction did

not technically complete because purchase monies were paid

to the fraudster without receiving genuine documents in return

(as per the decision in Lloyds TSB Plc. v Markandan & Uddin

(2012)). The result was that Santander (S) received no security

for its advance of £150,000.

Honesty of solicitors not enough to invoke court’s mercy

01

02

of section 61 rests upon the trustee, who must show that

he acted honestly and reasonably throughout, and ought

reasonably to be excused from liability. In the context

of mortgage fraud, the Appeal Court has interpreted

section 61 as requiring the trustee to prove that he acted

reasonably in relation to those aspects of his conduct which

are connected with the beneficiary lender’s loss. The CA

was therefore required to consider precisely what type of

‘connection’ section 61 required. The standard to be applied

to conduct connected with loss is that of reasonableness,

not perfection (Davisons).

Connection between conduct and loss

Briggs LJ said that a strict causation test between an action

and the loss “casts the net too narrowly for the purpose of

identifying relevant conduct. In most mortgage fraud cases,

the effective, primary or predominant cause of the loss is

the third party’s fraud rather than the conduct of the solicitor

trustee.”

It was “also too restrictive to apply a ‘but for’ test which

disregards conduct, however unreasonable, on the basis

that even if the solicitor had acted reasonably, the fraud,

and therefore the loss, would still have occurred.” Briggs

LJ said that “it would not be appropriate to exclude as

irrelevant conduct which consisted of a departure from

best or reasonable practice which increased the risk of

loss caused by fraud, even if the court concludes that the

fraudster would nonetheless have achieved his goal if the

solicitor had acted reasonably.”

On the other hand, it would “extend the net too wide if it

accommodated every aspect and detail of the solicitor

trustee’s conduct which occurred, or played any part in, the

process which began with the transfer of the loan money by

the lender to the solicitor trustee and ended with its theft by

the fraudster”

Between those extremes, “some element of causative

connection will usually have to be shown, and that conduct

(even if unreasonable) which is completely irrelevant or

immaterial to the loss will usually fall outside the court’s

purview under section 61.”

S therefore sued R for breach of trust, since it was a

requirement of the CML Handbook that it hold the loan on

trust ‘until completion’.

The High Court decision

The lower court followed the earlier decisions in Davisons

(Solicitors) v Nationwide (2012) and Markandan. Smith J

held that in releasing the purchase monies to Sovereign,

R acted in breach of trust, albeit in the genuine belief that

completion was taking place on that day. R did not dispute

that it had acted in breach of trust, but applied for, and at

first instance obtained, relief under section 61. The court

held that they ought fairly to be excused from liability

because S’s loss was in substance caused by the fraud of

Sovereign. Although R had a number of failings, there was

not a sufficient connection to the loss suffered.

Legal principlesCourt of Appeal decision

The CA reversed the decision to grant section 61 relief.

Reasonable conduct required

The CA concluded that, although it had acted ‘honestly’,

R had not acted ‘reasonably’ in order to obtain relief

under s.61. Its failings had represented departures from a

sophisticated conveyancing regime intended to minimise

the risks of loss to lenders and lay clients.

The trial judge was too lenient on the requirement to show

reasonable conduct. He had incorrectly attempted to

construe s.61 by reference to the similar, but by no means

identical, relieving provisions in the Companies Act. Smith

J’s exercise of discretion could not stand.

Since R had not shown that it acted reasonably in all

respects connected with S’s loss, the discretion did not,

strictly, arise at all.

Lord Justice Briggs gave the lead judgment in the CA. He

considered the strict liability imposed by breach of trust,

tempered by the ability to claim relief under section 61.

He reiterated that the burden of proof for the purposes

03

R’s numerous departures from best practice included

inadequate making of requisitions on title, transferring the

completion money without adoption of the Completion

Code by Sovereign, and then failing to deal with the absence

of a prior mortgage discharge on the purported completion.

R’s failings formed part of a larger picture of the “shoddy

performance of a conveyancing transaction from start to

finish”, which left the court in no doubt that it would not be

fair to excuse the firm from liability, in whole or in part.

Effect on the beneficiary

The second main stage of the section 61 analysis, usually

described as discretionary, consists of deciding whether

the trustee ought fairly to be excused for the breach of

trust. This requires the court to consider the effect of the

grant of relief not only upon the trustee, but also upon the

beneficiary. LJ Briggs commented “in this context mercy

lies not in the free gift of the court. It comes at a price.”

Although lenders may have insurance arrangements in

place, an innocent purchaser may lose his life savings in a

mortgage fraud. The effect on the beneficiary is therefore an

important consideration.

CommentaryThe Court of Appeal’s decision bucks a recent trend where

the courts have granted relief under section 61 to innocent

conveyancing solicitors (Davisons, Ikbal v Sterling Law

(2013)). The CA did however note that the departures from

best practice in Davisons were far less serious.

Lenders will welcome this decision, but professional

indemnity insurers will be disappointed by it. The

decision highlights the onerous responsibilities residential

conveyancing solicitors have to their clients in respect of the

possibility of fraud by third parties.

Any shortcomings of the conveyancing solicitors will be

relevant in deciding if the firm has acted reasonably for

section 61. It appears that the threshold for obtaining such

relief is high.

The CA however cautioned against an over-mechanistic

application of the requirement to show the necessary

connection between the conduct complained of and the

lender’s loss. “There may be highly unreasonable conduct

which lies at the fringe of materiality in terms of causation,

and only slightly unreasonable conduct which goes to the

heart of a causation analysis.” It would be wrong to exclude

the former from any consideration under section 61.

It is therefore vital that conveyancing solicitors have systems

in place to ensure compliance with established conveyancing

best practice procedures and lender requirements. To prove

that he acted reasonably under section 61, the solicitor will

need to be able to provide a paper trail demonstrating that

the whole of his or his firm’s conduct sufficiently connected

with the loss satisfied the reasonableness test.

Santander UK plc. v RA Legal Solicitors [2014] EWCA

Civ 183

04

The financial services industry breathed a collective sigh

of relief following the recent Court of Appeal decision in

Clark v In Focus Asset Management. The financial advisers,

In Focus, successfully appealed against the High Court’s

decision, which allowed a complainant to seek further

redress through the courts, despite acceptance of a final

award by the financial ombudsman.

The financial ombudsman dispute resolution scheme was

set up in order to deal with consumer complaints against

financial advisers and financial service providers, such

as banks, insurers or investment services. The Financial

Ombudsman Service (FOS) determines disputes and may

award compensation. The scheme is very important to

consumers, not least because it is free to them.

BackgroundThe Clarks (C) complained to the FOS about advice

received from In Focus (F) on an endowment plan. They

considered their losses to be in excess of £300,000 as a

result of negligent investment advice. The ombudsman

decided that they were entitled to compensation, but could

only award £100,000 which was the financial limit of the

FOS at the time. The ombudsman also made a non-binding

recommendation that F should pay C the full compensation.

C accepted the £100,000 but reserved their right to claim

more in court proceedings. F paid the £100,000 but not the

full recommended amount. In June 2010, approximately

eight weeks later, C issued county court proceedings for the

balance. F applied to strike out the claim.

Lower court decisions

The Clarks’ claim was originally dismissed by HHJ Barratt

QC who followed the decision in Andrews v SBJ Benefit

Consultants (2011) and held that the doctrine of merger

applied. This doctrine provides that if a court or tribunal

gives judgment on a cause of action, it is extinguished.

A claimant cannot bring a second set of proceedings for

losses incurred under the same cause of action even if the

first tribunal awarded him less than he was entitled to.

On appeal to the High Court, Mr Justice Cranston disagreed

with the decision in Andrews. Cranston J reinstated the

proceedings allowing the complainants to pursue the same

claim for additional compensation in the courts, effectively

allowing them a second bite at the cherry.

The High Court did not follow the decision in Andrews. It held

that a complainant should not be precluded from pursuing

the matter further in the courts on the basis that the FOS

only dealt with complaints and was not a judicial tribunal.

It did not deal with causes of action as such and did not

need to apply the strict law when reaching a decision. An

additional factor was that the complainant could ultimately

choose whether to be bound by the decision which was not

indicative of a formal tribunal process

Legal principlesCommon law doctrines preclude a person who has obtained

a decision from one court or tribunal from bringing a claim

before another court or tribunal for the same complaint.

These rules are referred to as res judicata or merger. Res

judicata means that a judicial body has already adjudicated

on the matter and it cannot be decided again. There is a

public interest in the finality of litigation and a private

interest that it is unjust for a defendant to be vexed twice

with litigation on the same subject matter.

Court of Appeal decision

The Court of Appeal (CA) had to determine whether

because of the doctrine of res judicata, acceptance of an

ombudsman’s award precluded a complainant from seeking

further redress through legal proceedings. The burden of

showing that the facts constituting a cause of action formed

the basis of an award, and that the same cause of action

A bird in the hand is probably worth two in the bush for FOS complainants

05

is relied on in court proceedings, will lie on the financial

adviser. If the court is not satisfied, there would be no res

judicata. In short, the complainant has the benefit of any

doubt.

The CA applied the doctrine of res judicata to rule that

acceptance of a FOS award, for whatever amount, precludes

a complainant from then bringing legal proceedings to

pursue a claim based on the same cause of action.

The CA held that the FOS was a judicial tribunal for the

purposes of the doctrine of res judicata. In reaching that

conclusion, the court noted, among other things, that the

ombudsman does not reach his decisions by reference

to strict legal principles but on the basis of what in his

opinion is fair and reasonable. The CA’s reasoning was that

the principles of res judicata apply as much to decisions

by the FOS as to decisions by the courts because the

Financial Services and Markets Act 2000 (FSMA), which set

up the FOS, does not exclude the common law doctrine

of res judicata. The FOS need not decide matters strictly

according to the law, but that does not, according to the CA,

prevent a res judicata arising with regard to causes of action

covered by the facts considered by FOS.

The complainant cannot use the FOS award as a fighting

fund for legal proceedings. Res judicata does not cease

to apply because the complainant could obtain a higher

level of compensation in court proceedings. C should have

rejected the FOS’s award, and used it as a bargaining tool to

try to negotiate more from F in court proceedings.

CommentaryThe Court of Appeal’s decision leaves open the possibility

that, where a complainant has two distinct causes of action,

he may be able to submit one to the FOS, while bringing

court proceedings in relation to the other. Defendant financial

advisers and their insurers therefore ought to seek sufficient

particularity on any complaints made to the FOS, so that a

clear cause of action can be established for purposes of any

res judicata arguments.

It must be noted that the doctrine of res judicata only

applies to FOS decisions accepted by the complainant.

A complainant can therefore seek, but not accept, a FOS

determination to assess its chances of success at court. A

favourable FOS decision could also be used to persuade

the defendant to settle the claim.

On the other hand, complainants may decide that a bird in

hand is indeed worth two in the bush. A secure award from

the FOS may be worth more than risking a higher award

through the courts particularly taking into account legal

costs. Complainants seeking damages awards far in excess

of the current £150,000 limit would be best advised to seek

legal advice prior to accepting any FOS award.

Clark & Anr v In Focus Asset Management & Tax

Solutions Ltd & Financial Ombudsman Service [2014]

EWCA Civ 118

06

Calderbank offer trumps part 36 in a construction dispute In Walker Construction (UK) Ltd v Quayside Homes Ltd &

another, the Court of Appeal overturned an order which

awarded a successful party its costs on an indemnity basis

after it had beaten its own, very low, part 36 offer.

It held that a costs order requiring a claimant to pay the

defendant’s costs of over £345,000, where the defendant had

only recovered a very small percentage of its counterclaim,

was disproportionate. There were strong grounds for

disallowing abandoned and unsuccessful elements of the

counterclaim and the judge had failed to give appropriate

weight to a Calderbank offer made by the claimant.

BackgroundThe claimant, Walker (W) is a civil engineering contractor.

The defendant, Quayside (Q) is a developer of residential

homes. In December 2004 W entered into a contract to

carry out drainage and highway works at Q’s building site.

In February 2008 W brought proceedings to recover

outstanding payments which had been retained by Q at the

conclusion of the project. W’s claim had originally started

out as a claim for approximately £25,000. Proceedings were

stayed pending adjudication and the adjudicator awarded

W approximately £23,400. Q paid the award but maintained

that W’s works were defective.

W’s claim then proceeded as a claim for the modest sum

of £1,773.65. In December 2010 Q served its amended

defence and counterclaim, which replaced its original

defence of March 2008 in its entirety. Q’s counterclaim was

substantial amounting to over £169,000.

On 5 January 2011 W made a Calderbank offer to pay Q

£30,000 including costs. On 3 May 2011 Q made a part 36

offer to settle its counterclaim for £100 plus costs. By that

date its costs were already in excess of £30,000. Shortly

before trial Q halved its counterclaim to £84,000.

Despite numerous further attempts by the parties to settle,

the court proceedings continued to trial in September

2012. At trial Q was awarded a net sum of £10,885 on

its counterclaim. W was awarded its costs up until the

adjudication. The judge found that Q had beaten its part 36

offer. W was to pay Q’s costs on the standard basis from

after the adjudication to the expiry of Q’s part 36 offer and on

the indemnity basis for the period from 25 May 2011 to trial.

It should be noted that the court treated the defendant’s

offer on its counterclaim in the same way as a claimant’s

part 36 offer, for the purposes of part 36 sanctions.

The defendant’s costs claim was over £345,000. W argued

that the judge’s approach to costs had produced a result

that was completely disproportionate to Q’s actual recovery

on its counterclaim.

Legal principlesLady Justice Gloster handed down the majority judgment

of the Court of Appeal (CA). She accepted that an appellate

court should not lightly interfere with a trial judge’s exercise

of discretion as to costs. However, the judge was plainly

wrong in this case and his costs order was unsustainable

for the following reasons:

1. When considering the history of the matter and

assessing the various offers, he had failed adequately

to take into account the commercial reality of the

litigation, how it was conducted on each side, its

ultimate outcome and who, on an objective basis,

was the more successful party. These were factors

he was obliged to consider under the relevant parts

of Part 44(3) of the Civil Procedure Rules. Q delayed

for two years in putting forward its amended defence

and counterclaim for over £169,000, before reducing it

shortly before trial to approximately £84,000. Q made

a net recovery at trial of only 5.93% of its original

claim, and 11.92% of its amended claim. Against that

07

background it was impossible that a proportionate result

could be that W should pay Q’s costs of over £345,000,

in circumstances where Q had failed to establish all but

a very small part of its counterclaim.

2. He had failed adequately to consider the respective

conduct of the parties of the litigation and adjudication

processes. The judge paid no regard to Q’s conduct in

pursuing an inflated claim or its delay in formulating its

claim.

3. Consideration should have been given to whether an

issue-based or partial costs order was appropriate in

the circumstances.

4. The judge, when considering the claimant’s Calderbank

offer dated 5 January 2011 did not appear to give

appropriate weight to the fact that W was left in a

position where it could not realistically have made a part

36 offer. A part 36 offer would have had the automatic

consequence that, if the offer were accepted, Q would

have been entitled to all its costs of the proceedings to

date. The counterclaim had been exaggerated and the

judge should have appreciated the commercial reality

of the situation. It would have been disproportionate

and unfair had W been liable under CPR 36.10 for all

costs of the proceedings if the offer was accepted. In

those circumstances a part 36 offer can have unjust and

disproportionate cost consequences. The court referred

to the decisions in Medway Primary Care Trust v Marcus

(2011) and Fairclough v Summers (2012) in this regard.

5. The judge failed adequately to consider whether W’s

Calderbank offer of £30,000 inclusive of costs had

represented a reasonable offer to settle. Given the

ultimate outcome, an offer to pay costs in a net sum of

£19,000 as at 5 January 2011 was in fact generous.

6. The judge’s conclusion that W should have accepted

Q’s part 36 offer and therefore pay the entirety of Q’s

costs from December 2008, on a standard and then

indemnity basis, was flawed. Although the judge

recognised that for W to have accepted the part

36 offer would have rendered W liable for a “wholly

disproportionate sum of costs”, he did not act on that

conclusion in making his award. There were strong

grounds for disallowing a substantial proportion of

Q’s costs relating to the abandoned or unsuccessful

elements of its counterclaim.

In circumstances where the judge has exercised his

discretion in a manner that is wrong in principle, it is for the

CA to exercise its discretion afresh. The judge should have

considered whether it was just to apply the sanctions set

out in part 36.

The CA therefore ordered W to pay 50% of Q’s costs on the

standard basis from December 2008 (after the adjudication),

to 19 January 2011 which was the date by which Q should

have responded to W’s Calderbank offer. The costs were

limited to January 2011 on the basis that this was when

the claimant had made a reasonable and proportionate

Calderbank offer.

Q was ordered to pay W’s costs from 20 January 2011 to

judgment on the standard basis.

CommentaryThis case is a classic example of the costs of litigation

spiralling out of all proportion to the value of the claims

in dispute. In the end, both parties were stung with

substantial costs for very little gain. It is not apparent why W

continued with court proceedings for only £1,773.65 when

it had succeeded on the vast majority of its claims at the

adjudication. It clearly cost significantly more to fight the

case than the claimant would ever recover.

The CA’s costs order against the successful defendant is

also a stark warning to parties to always bear in mind the

overriding objective of proportionality.

The CA referred to the judgment of Summers v Fairclough

in recognising the practical limitations of part 36 where a

party is faced with an exaggerated or potentially fraudulent

claim. The Civil Procedure Rules do not allow for a costs-

inclusive part 36 offer. The judgment is therefore a helpful

endorsement of the use of Calderbank offers in those limited

circumstances where the use of part 36 is inappropriate.

08

The CA was not impressed by Q’s submissions that a

Calderbank offer could not be all-inclusive, that it could not

provide costs protection or that, for the judge to have paid

more regard to W’s Calderbank offer, would have wrongly

elevated Calderbank offers to the same status as part 36

offers. The court found that “in the particular circumstances

of the present case” a part 36 offer would have been

disproportionate and unjust. It therefore saw no reason why

requirements of certainty or the desirability of the clarity

which a part 36 offer provides, should prevent a judge from

properly analysing the effect of a party’s Calderbank offer.

This decision is therefore helpful to defendants faced with

an exaggerated claim. A part 36 offer is certain to give costs

protection unless the court considers such an award unjust.

Therefore, settlement offers under the part 36 regime are still

the preferred option but not the only option. A Calderbank

offer made outside the part 36 regime is less certain, being

reliant on the court’s discretion but it can still be an effective

tool as this decision amply demonstrates.

Walker Construction (UK) Ltd v Quayside Homes Ltd (1)

& Peter Brett Associates LLP [2014] EWCA Civ 93

09

The history of any relationship is important, particularly one

in a professional negligence context. Whether a professional

owes a duty of care cannot be answered, without first taking

into account the particular circumstances in which that

professional came to be involved. This helps to determine

the proximity of the relationship.

The legal concepts of proximity and foreseeability were

examined in the recent Court of Appeal decision of

Harrison v Technical Sign Co Ltd. The case considered

when a professional surveyor might owe a duty of care to

potential injured parties to take reasonable steps to prevent

foreseeable harm to them.

BackgroundIn June 2007 the fascia on Maison Blanc patisserie’s (M)

shopfront in Putney became detached from the building

and fell to the pavement, causing serious injuries to two

members of the Harrison family who were passing by. The

Harrisons brought proceedings against the shop owner

M and three other defendants for breach of duty of care.

The defendants included Technical Sign Company Limited,

which had supplied and fitted the shop sign and Active

Commercial Interiors Ltd who had carried out a remodelling

of the shopfront, including the fascia, in 2005. The last

defendant was the surveyor firm, Cluttons.

Lower court decision

The lower court held that a reasonably competent surveyor

would have foreseen that a failure on his part to inspect

a shopfront with reasonable skill and care, might cause

physical injury to passers-by. The surveyors knew the

premises and its close proximity to the road. They would

have appreciated that a failure to inspect and advise on

a defect in the frontage of the premises could result in

potential injury to pedestrians. The judge apportioned 11%

of the total liability to the surveyors.

Surveyors escape liability for injured pedestrians Appeal Court decision

The Court of Appeal (CA) disagreed with the trial judge,

finding that Cluttons did not owe a duty of care to the public

or to M. It found that the relationship between Cluttons and

M was insufficient to sustain a finding that the surveyors

owed a duty of care to the owners or passers-by. The court

emphasised that proximity is an essential component of a

duty of care and that foreseeability of harm is not sufficient.

Legal principles The question of whether the surveyors owed a duty of care

to the public could not be answered without taking into

account the circumstances in which Cluttons had become

involved.

Duty of care to the claimants

Cluttons had inspected the awning over the shop window

for damage in March 2007. They had done so as agents

of the landlord of the property, at M’s request. Cluttons’

surveyor had visited the shop for the limited purpose

of investigating a complaint that the awning had been

damaged by the landlord’s workmen. This is the context in

which the relationship between Cluttons and members of

the public was to be determined. The surveyor’s role was

simply to see whether the shop-front had sustained damage

for which their client (the landlord) might be liable, and there

was not a sufficient degree of proximity between them and

the claimants to give rise to a duty of care.

The trial judge erred in placing too much emphasis on

foreseeability of harm. He did so almost to the point of

treating it as sufficient to create a relationship of proximity

between Cluttons and passers-by. However, foreseeability

on its own is not enough. Following the principles set out

in Caparo v Dickman (1990), even where physical injury

is concerned, the existence of a duty of care requires a

relationship of proximity or ‘neighbourhood’.

010

Duty of care to Maison Blanc

The trial judge’s finding that Cluttons had undertaken a

responsibility to M to inspect the shopfront and report its

findings, and in so doing to act with reasonable care and

skill, lay at the heart of his analysis. On that basis, M would

in effect become a client of Cluttons, at least for that limited

purpose. However, the CA noted that the relationship

between them was essentially adversarial in nature, not one

of a professional adviser and client.

Cluttons was approached as agents of the landlord rather

than as surveyors, for M to make a claim in respect of

damage that it thought had been caused by the landlord’s

workmen. M had complained that the awning was not

opening properly and had been damaged. Cluttons’ concern

was therefore with the awning. There was no evidence to

suggest that they had been asked to advise M in relation

to the condition of the shopfront in general, or that a

relationship of professional adviser and client had come into

existence. The nature of the relationship was inconsistent

with an assumption of responsibility by Cluttons.

CommentaryThe decision provides helpful guidance on when a surveyor

will owe a duty of care to third parties. It is also a reminder

that there are limited circumstances in which the courts will

impose on a party a duty of care to someone who is not

their client.

It is necessary to look closely at the relationship between the

professional and those to whom he is alleged to owe a duty

of care, to see whether the requirements of foreseeability

and proximity exist. The particular circumstances in which

Cluttons became involved in this case were not sufficient

to satisfy the requirement of proximity. However, the Court

of Appeal commented that had Cluttons been asked by M

to inspect the awning on its behalf to ensure there was no

risk to pedestrians, a sufficient degree of proximity would

probably have arisen. The very purpose of the inspection

would have been to ensure the safety of the public and an

assumption of responsibility may well have arisen.

Harrison & Ors v Technical Sign Co Ltd & Ors [2013]

EWCA Civ 1569

The information and opinions contained in this document are not intended to be a comprehensive study, nor to provide legal advice, and should not be relied on or treated as a substitute for specific advice concerning individual situations. This document speaks as of its date and does not reflect any changes in law or practice after that date. Plexus Law and Greenwoods Solicitors are trading names of Parabis Law LLP, a Limited Liability Partnership incorporated in England & Wales. Reg No: OC315763. Registered office: 8 Bedford Park, Croydon, Surrey CR0 2AP. Parabis Law LLP is authorised and regulated by the SRA.

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