23 April 2015

Date of Claimant's letter to CIArb seeking appointment of arbitrator

 

(accompanying form is dated 22 April 2015-p. 134)

p. 132

28 April 2015

CIArb acknowledged Claimant's request for appointment of arbitrator.

 

(Claimant now contends in the part 8 claim that the Defendants substituted a "false and invalid date" of 28 April as the date when the application was received- see p. 603)

Letter at p. 22-27 and acceptance doc at p. 130

22 May 2015

CIArb invited Mr Bellamy to accept appointment as arbitrator. Mr Bellamy accepted appointment.

p. 128

26 May 2015

Mr Khan of the CIArb notified Claimant that Mr Bellamy had been appointed.

 

By the Part 8 claim the Claimant now contends that this was in breach of s. 16(3) of the Arbitration Act in that it was more than 28 days after his application was received- p. 603

 

CIArb had no further involvement until Oct 2015.

p. 28

 

(terms                  of

appointment     p. 30)

15 June 2015

Mr Bellamy expressed preliminary view that the law of the arbitration was English law because of the incorporation of CIArb rules by the arbitration clause.

p. 215 (details in ws)

1 July 2015

Claimant wrote to Mr Bellamy arguing that the law of the arbitration was UAE law. He requested a documents only procedure.

p. 215 (details in ws)

3 July 2015

Mr Bellamy wrote to Claimant acknowledging that the lex arbitri was UAE law and providing his terms of appointment (which included an indemnity for Mr Bellamy for any matter related to the arbitration, save in relation to the consequences of bad faith). Claimant signed and returned the terms on 12 July 2015

p. 216 (details in ws)

11 July 2015

Mr Bellamy signed terms of appointment as arbitrator

p. 35

29 July 2015

Mr Bellamy suggested procedures/timetable for arbitration

p. 215 (details in ws)

14 Aug 2015

Mr Bellamy's clerk requested payment of his fees to the end of July 2015 plus a £20,000 deposit. On 17 Aug Claimant refused to pay the deposit.

p. 217 (details in ws)


17 Aug 2015

First directions order.

 

Mr Bellamy recognised that governing law of arbitration was UAE law and that there should be an evidential hearing in Dubai. He listed the principal issues and established a timetable for documents.

p. 37

25 Aug 2015

Mr Bellamy's clerk repeated request for £20,000 deposit.

p. 218 (details in ws)

1 Sep 2015

Second directions order. Mr Bellamy ordered a hearing in Dubai on the law applicable to the exchange contract- namely whether it was UAE Law or Indian Law. Hearing also to deal with principal issues listed in order.

p. 41

11 Sep 2015

Claimant protested that demand for £20,000 deposit was premature and repeated request for documents only hearing.

p. 218 (details in ws)

15 Sep 2015

Mr Bellamy's clerk repeated request for £20,000 deposit. Claimant refused.

p. 218 (details in ws)

21 Sep 2015

Mr Bellamy's clerk made clear that Mr Bellamy was entitled to an advance for his fees and expenses.

p. 219 (details in ws)

22 Sep 2015

Claimant objected to the email from Mr Bellamy's clerk and indicated that he was disabled.

p. 219 (details in ws)

23 Sep 2015

Mr Bellamy's clerk repeated request for fees.

p. 219 (details in ws)

29 Sep 2015

Claimant objected to request for money or a hearing in Nov.

p. 219 (details in ws)

2 Oct 2015

Third directions order- Mr Bellamy made order stating that his work would be suspended unless payment was made by 9 Oct

p. 44 and p. 49

 

p. 219 (details in ws)

15 Oct 2015

Claimant indicated intention to bring a claim against Mr Bellamy for negligent breach of the arbitration procedure, failure to perform his duties and bad faith.

p. 220 (details in ws)

21 Oct 2015

Mr Bellamy resigned as arbitrator and suggested the parties consider appointing an alternative.

p. 51 or p 752

22 Oct 2015

Claimant argued that the consequence of the resignation would be "denial of the issue of an award". He repeated his allegations of breach of the arbitration agreement and bad faith against Mr Bellamy.

 

CIArb emailed Claimant stating that Mr Khan had left the CIArb and that Ms Williams had taken over as head of the dispute

p. 220 (details in ws)


 

appointment service. She gave Claimant details of what to do if he wanted to commence a fresh arbitration.

 

26 Oct 2015

Claimant wrote lengthy email complaining about Mr Bellamy and CIArb. He complained he had been the subject of discrimination/harassment and/or breaches of his human rights.

p. 750

10 Nov 2015

CIArb wrote to Claimant stating that it does not administer arbitrations, and denying breaches of the Equality Act/ECHR. CIArb also relied on s. 74 of the 1996 Act. Claimant later complained that the letter was misleading (including in his response date 13 Nov 2015).

p. 52 or p. 753

9 Dec 2015

First Judicial Review: Claimant commenced judicial review proceedings against CIArb, Mr Bellamy and his clerk (Mr Davidson). He complained the arbitration had been conducted in an unfair and discriminatory way and sought 2,983,685,978,715,270.00000kgs of gold plus damages for non- pecuniary losses valued at £196,000.

 

Claim contended that the defendants had acted negligently, in bad faith and had breached the Claimant's rights. The Claimant set out a detailed chronology of the arbitration.

 

CIArb instructed RPC (and in particular Mr Naylor) to defend the claim.

p. 754

2016

 

 

20 Jan 2016

McGowan J dismissed Claimant's application for permission to bring the First Judicial Review Claim as "totally without merit"- none of the Defendants was a public body . Claimant ordered to pay costs on indemnity basis: order noted that "the Claimant was advised that this claim had no merit but insisted that he would pursue it".

p. 53 or p. 760

10 March 2016

Claimant was ordered to pay costs of the judicial review application (which he failed to do). Simon Bryan QC (sitting as a deputy High Court Judge) depicted the Claimant's costs arguments as "without merit". He said it was a "classic case for indemnity costs".

p. 761

3 May 2016

Bellamy Claim Claimant issued proceedings against Mr Bellamy, Mr Bellamy entered a defence.

 

Claimant sought 583,387,844,759,442,000,000,000kg of gold (or more than the total amount of gold ever mined in the world).

 

Alternatively Claimant sought £74,592,149,467,881.8m.

 

Claim based on breach of contract, tort or bailment plus additional small claim for personal injury. Claimant complained that Mr Bellamy had failed to act fairly during the course of the

p. 764


 

arbitration and had also unfairly resigned. Claim sets out a detailed chronology of the arbitration.

 

Claimant complained, among other things, of:

 

a)       Timings of hearings and alleged breaches of the UAE Civil Procedural Code (para. 6 and 9)

 

b)      The arbitration having been rendered void by the alleged breaches of the Code (para. 10)

 

c)       Being misled, in breach of consumer protection legislation (para. 11)

 

d)      An unfair or incorrect procedure being adopted (paras. 17-33)

 

e)      Disability discrimination/breach of Equality Act (paras 33-41)

 

f)        Repudiatory breach of contract (paras. 41-46)

 

g)       Illegal acts of bad faith (para. 47)

 

h)      Breaches of the Fraud Act 2006 in respect of the arbitration procedure (paras. 53-58)

 

i)        Misrepresentation in relation to the "void" arbitration proceedings, and procedural irregularity (paras. 59-67)

 

j)        Breaches of Consumer Protection Legislation (paras. 67-73)

k)       Bad faith in the conduct of the arbitration (paras. 74-76) The Claimant claimed damages for personal injury of

£74,592,149,467,881,800,000 (para 77.k.i at p 793) plus other

losses such as injury to feelings of £148,000 (para. 77.k.ii at p. 794) or loss of utility (also £148,000) (para. 77.k.iii at p 795)

 

Master Kay QC later found that the claim against Mr Bellamy was "very poorly pleaded and?falls to be struck out". Master Kay QC found that Mr Bellamy had immunity from suit under s 29 of the 1996 Act and that there was no proper evidence of bad faith.

 

31 May 2016

Defence entered to Bellamy Claim

p. 225 (details in ws)

24 June 2016

Weightmans informed Claimant of intention to apply to strike out claim against Mr Bellamy. Letter also referred to the

directions questionnaire and the fact that it was their practice

p. 54 or p. 1201


 

to use standard disclosure rather than electronic document questionnaires.

 

27 June 2016

Mr Bellamy's "disclosure report" i.e. setting out in a table the core types of documents that he held. The matter never in fact reached the stage of giving disclosure (because it was struck out)

p. 1203

29 July 2016

Mr Bellamy applied to strike out the claim against him

p. 225 (details in ws)

11 Aug 2016

Lindblom LJ refused Claimant permission to appeal against the order of McGowan J. Claim found to be "totally without merit" and "patently unarguable".

p. 64 or p. 763

25 Aug 2016

Supreme Court refused permission to appeal (RPC having pointed out that the Supreme Court lacked jurisdiction in any event).

p. 349 (ref to in another order)

21 Oct 2016

Claimant applied to bring a claim before the European Commission

p. 66

27 Oct 2016

Claimant contacted CIArb to ask for addresses of 2 employees whom he wanted to serve with legal proceedings- namely (Mr Khan and Mr Udoh). By this stage both Mr Khan and Mr Udoh had left CIArb.

 

RPC refused to divulge the information and asked the Claimant to correspond with them.

 

Claimant also began to prove RPC's retainer.

p. 797-798

12 Dec 2016

First Joinder Application: Claimant applied to join CIArb, the President of the CIArb RPC and Mr Naylor to the claim against Mr Bellamy (collectively- the "Proposed Joinder Defendants").

 

Claim against Proposed Joinder Defendants based on:

 

a)       alleged bailment of gold (paras (5) -(8))

 

b)      an alleged ongoing role as regards the arbitration after the appointment of Mr Bellamy (para (11))

 

c)       alleged conspiracy between Mr Bellamy and the CIArb (para 20)

 

d)      the assertion that the arbitration was void (para. (22))

 

e)      complaints about Mr Bellamy's conduct of the arbitration (paras. (21) to (34)

p. 808


 

f)        Complaints about the handling of Mr Bellamy's resignation including representations on the part of the CIArb about its role (paras. (36) to (41))

 

g)       Complaints about RPC/Mr Naylor allegedly providing the Claimant with false information in August 2016 (para (52) or refusing to answer data requests (para. (64))

 

The Claimant sought damages of the "Monetary currency equivalent of 583,387,844,759,442,000,000,000 kg of 99.9%

pure gold bullion (para (67) and (70) at p. 819 and 820) plus damages of £1,612,399 (para. (70) at p. 820).

 

12 Dec 2016

Skeleton argument in support of First Joinder Application. Claim based on bailment of the gold, apparently based on Mr Bellamy's and the then CIArb/RPC Defendants' breaches relating to arbitration procedure (paras 1-23)

p. 799

15 Dec 2016

Mr Bellamy obtained interim charging orders over the Claimant's property (in relation to Judicial Review costs)

p. 70, p. 222 (ws)

2017

 

 

4 Jan 2017

Claimant attempted to cancel unilateral notices relating to Mr Bellamy's charging orders

p. 222

16 Jan 2017

Ex parte order made in favour of Claimant transferring claim in QB to Commercial Court - Mr Bellamy later objected

p. 66

30 Jan 2017

Freezing injunction application: Claimant applied for "interim relief under CPR 25.6 and for delivery up or preservation of evidence or property under CPR 25 PD 8.1".

 

The application was ostensibly against Mr Bellamy, but Claimant's draft order also sought relief against the current and past Presidents of CIArb and CIArb itself. The application seems to have been founded on the misapprehension that Mr Bellamy, CIArb and the Presidents of CIArb were detaining Claimant's gold and ought to be subject to worldwide freezing orders up to the value of £366,885,123,328,168,000.00.

p. 822

 

 

 

draft order at p. 826

1 Feb 2017

The Honourable Mr Justice Males dismissed the freezing injunction application as "totally without merit" and depicted it as "absurd"

 

(the Appellant unsuccessfully tried to appeal this order)

p. 839

10 Feb 2017

Second Joinder Application: Claimant applied "to join parties, transfer case C34YP857 to the action, multi-track the issues and interim payment".

p. 66 or p. 840


 

Application included allegations of a conspiracy involving Mr Bellamy, Weightmans, Mr Gaul and Ms Hillyard of Weightmans, RPC, Mr Naylor of RPC, CIArb and Mr Udoh to wrongfully interfere with Claimant's goods or to cause him harm. Claimant made allegations of fraudulent or dishonest representations against Mr Udoh (para. 14).

 

Claimant also complained about the conduct of Weightmans (para. 22) and RPC (para. 23), including asserting that various lawyers had used the judicial process to commit fraud or dishonesty with the intention of penalising the Claimant for his ethnicity. He also alleged that there had been a "failure to disclose truthful information".

 

Claimant accused Mr Bellamy and his solicitors Weightmans of a "plan to torture me" (Para. 25).

 

Claimant expressed a fear that this gold bullion was being detained or obstructed by a wide range of lawyers as well as defendants/ intended defendants (para. 28).

 

The Second Joinder Application extended to more parties than the First Joinder Application.

 

17 Feb 2017

Criminal Convictions Application: Claimant applied for summary criminal conviction" of Mr Bellamy, his solicitors Mr Gaul and Ms Hillyard of Weightmans (plus Ms Hillyard's

supervisor), CIArb, RPC, Mr Naylor of RPC and Mr Udoh of CIArb.

p. 230 or p 851

 

 

The witness statement in support reiterates numerous complaints about e.g.

witness

statement at p. 860

 

a) the conduct of the arbitration (e.g. paras. 2-5)

 

 

b) alleged criminal acts on the part of Mr Bellamy and/or the CIArb (para. 3 or 7-8)

 

 

c)    the unlawfully deprivation of the Claimant of his gold (para. 5 and 16 or 26)

 

 

d) fraudulent representations by CIArb about their immunity (para. 9)

 

 

e) fraudulent false representations by RPC during the judicial review (para. 12)

 

 

f)     fraudulent    failures     by     Weightmans     to     disclose information (para. 15)

 

 

g) fraudulent acts by Weightmans in obtaining charging orders (para. 27-37)

 


 

h) race and disability discrimination (para. 39)

 

March/April 2017

Hearing before Master Kay QC. Hearing of Mr Bellamy's strike out application and the Claimant's Joinder Application.

 

The Proposed Joinder Defendants resisted joinder to the claim against Mr Bellamy on the grounds that:

 

a)       The claim against Mr Bellamy was hopeless

 

b)      The claim against them was also hopeless.

 

CIArb/President of the CIArb relied on

 

a)       The immunity in s. 74 of the 1996 Act

 

b)      The fact that allegations of bad faith against them had no or no real prospects of success

 

c)       The fact that the allegations of bailment (of gold) against them were ill founded and had been rejected by Males J as "absurd".

 

RPC/Mr Naylor relied on:

 

a)       The fact that they were acting for Claimant's opponent not Claimant

 

b)      The fact that allegations of bad faith against them had no or no real prospects of success

 

c)       The fact that the allegations of bailment (of gold) against them were ill founded and had been rejected by Males J as "absurd".

 

d)      The lack of evidence that they had acted in breach of confidentiality or privilege or the Solicitors Accounts Rules.

 

The Proposed Defendants also sought a Limited Civil Restraint Order ("LCRO") and transfer of the matter to a High Court Judge to make an Extended Civil Restraint Order ("ECRO"}.

 

Claimant sought an interim judgment in the sum of £24,000,000

 

4 April 2017

Witness statement of Patrick Gaul of Weightmans explaining why permission for the Claimant to appeal against the order of Males J dated 1 February 2017 (relating to the freezing injunction) should be refused. Witness statement attached schedule of applications/ orders to date.

 

Claimant now complains about this statement.

p. 66 or p. 1205


7 July 2017

Order of Master Kay QC.

 

Claim against Mr Bellamy dismissed as "totally without merit". Judgment was entered for Mr Bellamy for outstanding fees plus costs on the indemnity basis.

 

Claimant's application for an interim payment of £24,000,000 from Mr Bellamy dismissed as "totally without merit".

 

Claimant's application to join the Proposed Joinder Defendants to the claim against Mr Bellamy dismissed as "totally without merit". Claimant was ordered to pay these parties' costs on the indemnity basis.

 

LCRO made. Save for permitting one application for permission to appeal against the order of Master Kay dated 7 July 2017 (and the pursuit of the appeal, if permission were granted), the LCRO prevented Claimant "for a period of 2 years from the date of this Order from making any further applications in the Bellamy Claim [i.e. HQ 16X0526] against Mr Bellamy or the Proposed Defendants without first obtaining the permission of Master Kay QC. For the avoidance of doubt this includes a restraint on any applications to join the Proposed Defendants or to seek any other relief against them (or Mr Bellamy) without first obtaining the permission of Master Kay QC."

 

Order amended under the slip rule on 11 July 2017.

 

Application for ECRO was transferred to a High Court Judge of the Commercial Court.

Judgment at p. 73 Order at 1/ p 89 (LCRO is at p. 92)

28 July 2017

Final Charging Order in Kingston-upon-Thames County Court arising from Mr Bellamy's application dated 11 Nov 2016 for Interim Charging Order (relating to Mr Bellamy's costs). Judge did not entertain Claimant's allegations of fraud.

p. 223 (details in ws)

31 July 2017

Order of Mr Justice Leggatt dismissing Claimant's application for permission to appeal against the Order of Master Kay QC of 7 July 2017 as "totally without merit".

 

"None of the grounds of appeal discloses any rational basis for arguing that there was any error in the Master's decision"

 

Claimant was refused the ability to make an oral application for permission to appeal.

p. 887

Undated

Claimant's Appellant's Notice against the Order of 31 July 2017 of Mr Justice Leggatt- attempting to appeal that order to the Court of Appeal.

 

Claimant's application alleged (amongst other things) that there had been "mala fides" and dishonest acts.

p. 890


 

Claimant's Appellant's Notice appeared to be in breach of the LCRO (which only permitted one application for permission to appeal against the order of Master Kay QC without permission from Master Kay QC).

 

Claimant's skeleton argument also accused the parties' legal representatives of wrongdoing. HE complained about the case put forward relating to the law governing the contract between the Claimant and the CIArb, which he said should be UAE Law and not English Law. He attacked the CIArb/President of the CIArb's reliance on immunity (para. 23-27)(p. 916).

 

Claimant sought the quashing of Master Kay's order

 

 

 

 

p. 912

17 Aug 2017

Letter from Civil Appeals Office to Claimant rejecting application for permission to appeal against the Order of Mr Justice Leggatt of 31 July 2017.

p. 231

17 Aug 2017

Appellant's Notice against the Final Charging Order of 28 July 2017.

 

Claimant's application alleged (amongst other things) that Mr Bellamy had failed to come to court with "clean hands" and attacked the decision of Master Kay dated 7 July 2017

 

(NB the decision of 7 July 2017 had not in fact given rise to the cost order in respect of which the Final Charging Order of 28 July 2017 was made but it formed part of Claimant's argument in the Appellant's Notice).

 

The Appellant's application also made numerous allegations of wrongdoing against Mr Bellamy's solicitors, Weightmans.

p. 223 (details in ws)

18 Aug 2017

Order of Mr Justice Males dismissing Claimant's Application for permission to appeal against the Final Charging Order of 28 July 2017. The application was certified as "totally without merit."

 

Mr Justice Males described the application as "self-evidently hopeless This is a collateral attack on an order from which

an appeal has already been certified by Leggatt J as totally without merit."

p. 924

6 Sept 2017

Second Judicial Review Claimant's application for judicial review of HM Courts and Tribunal Service as regards the Orders of Master Kay QC and Mr Justice Leggatt. The application made numerous allegations of dishonesty and fraud.

p. 926

6 Sep 2017

Claimant's application regarding judicial review of the Final Charging Order and the Order of 18 Aug 2017 of Mr Justice Males. Application made numerous allegations of wrongdoing against Weightmans.

p. 928


22 Sep 2017

Claimant's applications for judicial review dated 6 Sep 2017 were refused on grounds that the court did not have jurisdiction to deal with his application (according to his application letter dated 31 Oct 2017).

p. 934

31 Oct 2017

Application by letter: Claimant's letter to the Queen's Bench Division/Master Kay QC but bearing both the QBD and Commercial Court claim numbers raising a large number of issues ("the 31 Oct 2017 letter"), including:

 

a)       Judicial review of the orders of 31 July 2017 (Leggatt J) and 18 Aug 2017 (Males J);

 

b)      Permission to lay a voluntary bill of indictment;

 

c)       Application for joinder of new parties;

 

d)      Application for parties to be summoned and reply and provide copies of documents to Claimant;

 

e)      A confiscation order;

 

f)        To set aside orders on grounds that they were procured by fraud;

 

g)       Relief under the Equality Act 2010 relating to alleged fraud.

 

Voluntary Bill of Indictment Application: Claimant's two applications for a "voluntary bill of indictment" seeking the criminal conviction of (i) the President of CIArb, (ii) members of the Board of CIArb, (iii) an employee of the CIArb (namely Mr Udoh) (iv) Mr Bellamy (v) Mr Naylor of RPC (vi) various of Mr Bellamy's solicitors from Weightmans (Mr Gaul, Ms Hillyard and Ms Sullivan) (vii) Mr Bellamy's counsel, Mr Liddell (vi) the Proposed Defendants' solicitor, Mr Wyles of RPC (vii) the Proposed Defendants' Counsel, Miss Evans (ix) Master Kay QC and (x) Sian Rees-Shepherd of the court service.

 

The proposed charges ran to 34 counts against the above defendants.

 

The lengthy skeleton argument included allegations that the CIArb had dishonestly misappropriated Claimant's bullion. It also accused Master Kay QC of breaking the Bar Code of Conduct and attempting to "make gain for himself or another, namely to make gain for the CIArb, RPC, Weightmans LLP through unlawful shielding of their defendants' assets and incurrence of litigation fees or to cause loss to Sayed Sanghamneheri and his family, namely loss of gold bullion". He also accused court staff of dishonesty,

p. 934

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

p. 938


 

Claimant's two applications for a voluntary bill of indictment were sent to (i) Queen's Bench Division and (ii) the Commercial Court. The application was then determined (by Master McCloud) in the Queen's Bench Division.

 

13 Nov 2017

Default costs certificate in favour of Mr Bellamy for costs of

£76,414.30 pursuant to the Order of Master Kay QC dated 7 July 2017

p. 192

15 Nov 2017

Order of Master McCloud (Queen's Bench Division) refusing Claimant permission to issue the "Voluntary Bill of Indictment", refusing permission to issue requests contained in letters sealed on 6 Nov 2017 and making consequential orders.

 

Master McCloud depicted Claimant's behaviour as an "abuse of the court process and misuse of court resources". She stated that if the application for the voluntary indictment amounted to an application to Master Kay QC for permission to issue a voluntary bill of indictment, it was "plainly hopeless".

 

Penal notice attached to the order.

 

LCRO varied to specify that no application for permission under it could exceed 1 side of A4 in length (to deal with the large volume of documents submitted by Claimant to the court- on that occasion exceeding 700 pages).

 

Papers referred to High Court Judge for consideration of an ECRO (unclear oif Master McCloud was aware of the hearing scheduled for 30 Jan 20187 in the Commercial Court to consider this issue).

p. 420 or p. 971

 

(see also ws at p. 231)

27 Nov      2017

(sealed 15 Dec

2017)

Claimant's application to set aside the default cost certificate in favour of Mr Bellamy. Application appeared to seek to present a further "voluntary bill of indictment" (notwithstanding the order of Master McCloud dated 15 Nov 2017).

 

8 Dec 2017

Email from Claimant to RPC and Weightmans seeking disclosure

p. 114

21 Dec 2017

Claimant's application in the Commercial Court for standard disclosure (against Mr Bellamy, the CIArb and the President of CIArb).

 

21 Dec 2017

Email of Jonathan Wyles of RPC to the court as regards the Claimant's specific disclosure application (which formed the basis of allegations of dishonesty by Claimant). The email pointed out that Claimant's application may be in breach of the

LCRO, may be an attempt to get early material for the hearing

p. 110


 

on 30 Jan 2018 and suggest that the application should not be dealt with on paper.

 

2018

 

 

10 Jan 2018

Fraud determination: Claimant's skeleton argument in support of an application for a "fraud determination" on 11 Jan 2018 in relation to his disclosure application dated 21 Dec 2017. The application largely focused on Mr Wyles of RPC. It alleged that he had made a false and fraudulent representation to the effect that Claimant's disclosure application was a breach of the ECRO.

p. 435 (details in ws)

17 Jan 2018

Email from SCCO to the parties that the hearing of Claimant's application notice of 15 Dec 2017 (to set aside Mr Bellamy's default costs certificate) had been adjourned pending determination whether it is in breach of the LCRO. The hearing had been scheduled for 25 Jan 2018.

p. 116

17 Jan 2018

Email from Claimant to Weightmans and RPC alleging that the hearings on 25 Jan 218 and 30 Jan 2018 had been "fixed to conduct proceedings for an offence/s including under the Fraud Act 2006". Claimant asserted that "both proceedings relate to my gold bullion/my property and to fraudulent acts."

p. 111

19 Jan 2018

Email from Claimant seeking to add allegations of contempt of court to his application to set aside the default costs certificate.

p. 116

22 Jan 2018

Email from Daniel Hull, Commercial Court, about what applications were due to be heard on 30 Jan 2018

p. 201

24 Jan 2018

Witness statement of Mr Wyles of RPC in relation to need for ECRO and the other applications then at issue.

p. 94

24 Jan 2018

Witness statement of Mr Bellamy in relation to need for ECRO and the other applications then at issue.

p. 211

30 Jan 2018

Hearing before Moulder J.

 

Moulder J imposed ECRO on Claimant (which lasted for 2 years).

 

Order contains helpful list of all of the proceedings held to be totally without merit by that stage.

 

Skeleton argument of Mr Bellamy and his lawyers is at p. 1153

p. 119 or p. 421

20 Feb 2018

Email from Claimant's solicitors to Weightmans about sale of his property (lender- Cooperative Bank)

p. 207

22 March 2018

Witness statement of Ms Sullivan of Weightmans opposing Claimant's application to set aside default costs certificate dated 13 Nov 2017

p. 193


24 May 2018

Hearing before Males J to deal with other loose ends (namely (i) the Second Joinder Application (ii) the Criminal Convictions Application (iii) any appeal against Master McCloud's refusal to allow the Voluntary Bill of Indictment (iv) any other appeal against Master McCloud's refusal to allow relief pursuant to the letter dated 31 Oct 2017 and (v) the "fraud determination"). Claimant's applications refused.

 

a)       Claimant acknowledged that he could no longer run a case based on bailment but tried to advance claim under Tort (Interference with Goods) Act 1977. Males J found that this was "obviously wrong", "manifestly hopeless", had already been determined, and that (if new) it was too late to run the claim in new ways (paras 9-14).

 

b)      Males J found that Claimant had accused Mr Bellamy, CIArb and their solicitors of "fraudulent and dishonest behaviour" in allegations that were "increasingly bizarre" (paras 15-21).

 

CIArb and related parties' skeleton argument for the hearing is at p. 429

 

The Claimant's skeleton argument is at p. 1087

Order is at p. 258 or p. 314

 

Judgment is at p. 449

22 Nov 2018

Final charging order in favour of Mr Bellamy

p.318

11 Dec 2018

Order by Flaux LJ dismissing Claimant's application to appeal against the order of Males J dated 24 May 2018

 

The allegation that the court had acted illegally was "scandalous and without foundation".

 

Application dismissed as "totally without merit".

 

Flaux LJ stated that as the Claimant continued to make applications to the High Court and Commercial Court which were totally without merit, he intended to make a further CRO against him

 

Further LCRO made, for a period of 2 years

p. 1006

 

 

 

 

 

 

LCRO at p. 1007

2019

 

 

1 July 2019

Deputy Master Leslie ordered the Claimant to pay £5,000 in costs

p. 320

2020

 

 

Jan 2020

Expiry of the ECRO imposed by Moulder J (although LCRO imposed by Flaux LJ still subsisted)

 


10 June 2020

Claimant wrote to CIArb complaining again about the conduct of the arbitration and claiming losses of £33.3 quadrillion worth of gold, plus an entitlement to rent calculated at

£74,592,149,467,881,800,000,000 upon the value of the gold (among other losses)

p. 1010

30 June 2020

RPC's reply to Claimant pointing out that he was repeating allegations he had already made

p. 1013

2021

 

 

16 March 2021

Claimant's email to Weightmans and RPC contending he had a new claim to bring against the defendants. He asserted that

 

a)       The judgment of Master Kay found (impliedly) that there had been more than 28 days between the service of the arbitration notice and the appointment of the arbitrator. This was a breach of s. 16 the Arbitration Act.

 

b)      English law did not apply to the CIArb Defendants pursuant to a Supreme Court judgment in Enka Insaat Ve Sanayi AS v Chubb (judgment October 2020). He complained that the defendants were liable in damages and/or had conspired with one another.

 

c)       He was therefore entitled to remedies under s. 25 of the Arbitration Act.

p. 287

13 April 2021

2021 Part 8 Claim: Claimant's Part 8 Claim against CIArb, President of CIArb, Khan, Williams, Udoh, Bellamy, complaining about matters relating to the 2015 arbitration

 

In particular the Claimant complained that

 

a)       The arbitration had not been properly conducted

 

b)      The law of the arbitration was UAE Law and other rules/procedures could not be followed

 

c)       The Defendants acted in bad faith by substituting the date on which the arbitration application was received and this rendered the arbitration void

 

Claimant had suffered "big losses, legal expenses and injurious anxiety". He claimed specific performance of 12039149111290600.000 g of gold (or £33.3 quadrillion)

 

Witness statement in support is at p. 3

p. 1 or p. 1014

14 April 2021

Claimant's certificates of service, Part 8 claim on CIArb Defendants and Mr Bellamy

p. 262-266


 

Claimant purported to effect service by email (in Weightmans' case, using the wrong email address)

 

26 April 2021

Mr Bellamy's acknowledgment of service in Part 8 Claim noting that Mr Bellamy intended to dispute the court's jurisdiction

 

Mr Bellamy's application for

 

a)       a declaration that the court has no jurisdiction over the Part 8 Claim as service had not properly taken place

 

b)      an order that that the Part 7 procedure should be used

 

c)       an order that the Part 8 claim be stayed pending payment of £199,339,38 in unpaid costs (arising from prior strands of the claim)

 

Witness statement of Ms Sullivan of Weightmans in support and explaining that:

 

a)       Claimant had used wrong email address (paras. 7-9)

 

b)      As far as Weightmans could tell, the claim appeared to revisit the matters that had already been litigated and that use of the Part 7 procedure was inappropriate (paras 17-20)

 

c)       The Claimant owed Mr Bellamy £199,330.38 in costs plus interest, which were unpaid (para. 21). These arise as follows:

 

·         £122,662.88 in final charging orders against the Claimant's property (in respect of which the Co- operative Bank has an order for sale)

 

·         £53,000 plus interest pursuant to the order of Males J dated 24 May 2018

 

·         £18,667.50 pursuant to the order of Master Nangalingham dated 28 March 2019

 

·         £5,000 pursuant to order of Deputy Master Leslie

p. 267

 

 

 

p. 269

 

 

 

 

 

 

 

 

p. 274

27 April 2021

Application by CIArb Defendants objecting to use of the Part 8 Procedure because the claim is an abuse of process and if it were not, it would involve a dispute of fact and evidence

p. 384

10 May 2021

ECRO made against Claimant in proceedings brought against him by Mr and Mrs Mason (unconnected with the present

proceedings). Order refers to 7 orders by a variety of judges

p. 1016


 

stating that the Claimant's applications were totally without merit.

 

19 May 2021

2021 Part 7 Claim: Claimant's Part 7 Claim against CIArb, President of CIArb, Messrs Khan, Williams, Udoh and Bellamy

 

The Part 7 Claim form had a general endorsement. No Particulars of Claim were produced. Claimant sought the sum of

£33.3 quadrillion. Claim complained that:

a)       the law of the arbitration was UAE law and

 

b)      the Defendants acted in bad faith by dishonestly substituting the date of service in 2015.

p. 385 or p. 1020

20 May 2021

Certificates of service in 2021 Part 7 Claim

p. 453- 60

24 May 2021

Witness statement of Jonathan Wyles of RPC opposing the 2021 Part 8 Claim on the following core grounds:

 

a)       Claim repeats matters already litigated

 

b)      Claim is an abuse of process

 

c)       New action would (if not struck out) involve disputes of fact and evidence between the parties

p. 389

9 June 2021

Email from Claimant to RPC and Weightmans raising issues with the date when the written notice of arbitration was received and contending that as Mr Bellamy had been appointed on 26 May 2015 this was more than 28 days after receipt of the notice and the arbitration was therefore void

p. 603

11 June 2021

Mr Bellamy's acknowledgment of service in 2021 Part 7 Claim

p. 461

15 June 2021

Email from Claimant contending that the Defendant's approach to his Part 8 claim was "lame" and "wrong". Claimant argued that the issues were not res judicata because the Master had not considered the procedure for appointing arbitrators

p. 600

18 June 2021

CIArb Defendants' acknowledgment of service in the 2021 Part 7 Claim

p. 462

21 June 2021

Claimant's Reply to Defence in Part 7 Claim. Document complained about the arbitration procedure, accused the Defendants of acting in bad faith and alleges that the arguments are not res judicata because Master Kaye did not consider whether the proper procedure for appointing arbitrators was complied with.

p. 463


 

Claimant argued that service of the Part 8 Claim was valid as the Commercial Court "works electronically" and has a CE Filing system.

 

22 June 2021

Mr Bellamy's application for:

 

a)       a declaration that the court has no jurisdiction to try the Part 7 claim as service had not properly been effected,

 

b)      an order that the claim form be set aside and in the alternative

 

c)       an order that the claim be stayed pending payment of

£199,330.38 in costs

 

Witness statement of Ms Sullivan in support:

 

a)       Paras 7-15 deal with correct service (on the wrong email address)

 

b)      Paras 16-20 deal with the     previous litigation and matters apparently raised in the current Part 7 Claim

 

c)       Paras. 21-24 deal with the costs orders (as per the April 2021 witness statement)

p. 470

 

 

 

 

 

 

 

 

p. 475

24 June 2021

Claimant's Defence to Mr Bellamy's application dated 22 June 2021.

 

He argued that the Part 8 proceedings had been properly served, sought to defend the allegations in the Part 8 claim and denied that any matters were res judicata. He alleged that disclosure showed that there had been "false substitution of dates"

p. 559

27 June 2021

Claimant's application for default judgment/for trial on Part 8 claim. Claimant repeated arguments about service/substitution of dates.

 

Claimant sought an order declaring the arbitration to be void ab initio and requiring the Defendants to deliver vast quantities of fine gold bullion to him in Dubai within 14 days

p. 565

 

 

 

 

p. 568

1 July 2021

CIArb Defendants sought an order requiring the Claimant to serve properly pleaded Particulars of Claim in Part 7 Claim

p. 580

6 July 2021

Claimant's reply relating to Part 7 Claim. Claimant alleged that the Defendants had

 

a) Substituted dates for the arbitration being commenced and failed to comply with s. 16 (3) of the Arbitration Act 1996

p. 619


 

b) Conspired against the Claimant and acted in breach of the Consumer Rights Act 2015 as well as the Arbitration Act 1996

 

The Claimant also argued that the Claims were valid and that the matters were not res judicata because of the alleged substitution of dates made in bad faith.

 

Claimant sought an order declaring the arbitration to be void ab initio and requiring the Defendants to deliver vast quantities of fine gold bullion to him in Dubai within 14 days

 

 

 

 

 

 

 

p. 623

7 July 2021

Weightmans' letter explaining that although the Claimant had not served the Part 8 and Part 7 Claims properly, Mr Bellamy no longer intended to contest service. The letter invited the Claimant to agree that the Part 8 claim be transferred to the Part 7 procedure and the matters stayed pending the payment of

£199,330.38 in costs.

p. 626

7 July 2021

Mr Bellamy's acknowledgment of service in the Part 8 Claim, instead objecting to the use of Part 8 Procedure and pointing out that the claim was an abuse of process

p. 631

7 July 2021

Mr Bellamy's acknowledgment of service in the Part 7 Claim

p. 632

7 July 2021

Claimant's letter to Weightmans accusing Mr Gaul and/or Mr Bellamy of acting in bad faith and concealing documents, namely the date when his application for an arbitration was received in April 2015. Letter claimed that Mr Gaul and Mr Bellamy were liable to him for at least £33.3 quadrillion.

p. 646

7 July 2021

Claimant's letter to RPC and Weightmans seeking their consent that his allegations should be dealt with on paper, including an order that the Defendants pay him £33.3 quadrillion.

p. 648

12 July 2021

Claimant's reply in relation to Part 8 Claim disputing that the Part 8 claim was an abuse of process and asking for a summary trial on an expedited basis. Claimant repeated his arguments over alleged substitution of dates/failure to comply with proper process for appointment of arbitrator

 

Claimant sought an order declaring the arbitration to be void ab initio and requiring the Defendants to deliver vast quantities of fine gold bullion to him in Dubai within 14 days

p. 635

 

 

 

 

 

 

p. 640

19 July 2021

Mr Bellamy's application seeking an order requiring the Claimant to file and serve properly particularised Particulars of Claim in the Part 7 Claim

p. 650


27 July 2021

Document purporting to be Particulars of Claim in Part 7 Claim. Main allegations as follows:

 

a)       Claim "primarily about the all [sic] and each of the Defendant's liabilities under the Main Contract to Arbitrate" (para. 4). Claim for specific performance of 12039149111290600.000gms of 99.9999% fine gold

 

b)      Claimant contended that the issues raised in the claim had "not been determined in another place" (para. 5)

 

c)       Claimant complained that the Defendants had falsely substituted the date on which the notice of arbitration had been received and failed to appoint an arbitrator quickly enough (paras. 9-12). The appointment of the arbitrator thereafter was unlawful, unfair and dishonest (para. 13). The arbitration thereafter proceeded on a dishonest basis (para. 14)

 

d)      The first hearing was fixed late and this conduct was dishonest (para. 15)

 

e)      Mr Bellamy "admitted" that the law of the exchange contract and arbitration agreement was UAE law and he was therefore "estopped" from changing the arbitration procedure (para. 16)

 

f)        Mr Bellamy's notice of the first hearing was in breach of UAE law (para. 17)

 

g)       Mr Bellamy resigned without lawful reason (para. 18)

 

h)      The CIArb/Mr Udoh made dishonest false statements in November 2018 (para. 18)

 

i)        In June 2016 Mr Gaul of Weightmans dishonestly contended he had made proper standard disclosure. On 15 February 2018 the Defendant discovered that he had not (para. 21)

 

j)        In April 2017 Mr Gaul of Weightmans made an untrue witness statement and deliberately concealed evidence (para. 24)

 

k)       In December 2017 RPC and Weightmans declined to provide further disclosure (para. 26) but in February 2018 Weightmans made further disclosure (para. 39)

p. 1043

27 July 2021

Further witness statement of Claimant. Claimant alleged (among other things) that:

p. 667


 

a)       The Defendants had falsely substituted the date of service/receipt of the arbitration notice (para 9)

 

b)      The Defendants had failed to appoint an arbitrator on time (para 12)

 

c)       Mr Bellamy's appointment was unlawful (para 13)

 

d)      The first hearing was not fixed quickly enough rendering the Defendants in breach of contract (para. 15)

 

e)      Mr Bellamy could not change the procedural law (para 16)

 

f)        The substantive hearing was not fixed quickly enough (para. 17)

 

g)       Mr Udoh made false statements to the Claimant in November 2015 (para. 19)

 

h)      Mr Bellamy/his solicitors made false statements about disclosure in 2016 and 2017 (para. 21)

 

i)        Master Kay QC reached his decision without the benefit of full evidence (para. 24)

 

j)        In December 2017 the parties' solicitors did not make further disclosure (para. 26)

 

k)       In February 2018 Weightmans disclosed previously concealed documents in the arbitration proceedings (para. 30)

 

27 July 2021

Claimant's application to join Weightmans and Mr Gaul as Defendants to the 2021 Part 7 Claim. Claimant alleged that Mr Gaul had made false statements about disclosure on 24 June 2016 and/or made false statements in his witness statement dated 4 April 2017.

p. 686

5 Aug 2021

CIArb Defendants' application to strike out/for reverse summary judgment on both the Part 8 and Part 7 Claims and for ECRO

 

Witness statement of Jonathan Wyles of RPC :

 

a)       Summarising the 10 previous lines of attack mounted by the Claimant on the arbitration proceedings (para 9)

 

b)      Explaining the similarities between the Part 8 proceedings and issues already raised/determined in the First Joinder Application (paras. 16-20)

p. 704


 

c)       Explaining the repetitious nature of the Part 7 claim (para. 22)

 

d)      Referring to the nonsensical size of the claims made (para. 26).

 

e)       Setting out the CIArb Defendants' arguments that the allegations against them are fanciful and weak (paras. 28-30)

 

f)        Explaining why a further ECRO is sought (paras. 34-36)

 

24 Aug 2021

Mr Bellamy's application to strike out/for reverse summary judgment on both the Part 8 and Part 7 Claims and for ECRO. Application adopts evidence of Mr Wyles of RPC.

 

Mr Bellamy argued that the 2021 claims were a repetition of the Bellamy Claim and/or were nonsensical.

 

Paras 18- 30 summarises the content of the 2021 Claims and compares them with the Bellamy Claim

p. 1052

19 Nov 2021

Cockerill J dismissed claim by Claimant against Cooperative Bank as totally without merit

p. 1179

26 Nov 2021

Order of Andrew Baker J in claim by Claimant against the Masons, imposing General Civil Restraint Order

 

Order described the present Part 8/Part 7 claim as appearing on its face to be "vexatious and fanciful"

 

Order to remain in force until 26 November 2023

p. 1179

2022

 

 

4 Mar 2022

Further witness statement of Ms Sullivan of Weightmans as regards the Claimant's application dated 27 July 2021 to add Weightmans and Patrick Gaul to the Part 7 claim.

 

Statement explained why the allegations against them are unmeritorious (para. 15-22)

p. 1185