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You are here: BAILII >> Databases >> First-tier Tribunal (Tax) >> Advanced Hair Technology Ltd v Revenue And Customs (COSTS - whether HMRC acted unreasonably in failing to withdraw its assessment to penalties in the light of evidence presented at the hearing) [2025] UKFTT 599 (TC) (29 May 2025)
URL: http://www.bailii.org/uk/cases/UKFTT/TC/2025/TC09539.html
Cite as: [2025] UKFTT 599 (TC)

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Neutral Citation: [2025] UKFTT 599 (TC)

Case Number: TC09539

FIRST-TIER TRIBUNAL

TAX CHAMBER

Decided on the papers

 

Appeal reference: TC/2018/04377

 

COSTS - whether HMRC acted unreasonably in failing to withdraw its assessment to penalties in the light of evidence presented at the hearing - Rule 10, Tribunal Procedure (First-tier Tribunal)(Tax Chamber) Rules 2009

 

 

Judgment date: 29 May 2025

 

Before

 

TRIBUNAL JUDGE ALEKSANDER

 

 

Between

 

ADVANCED HAIR TECHNOLOGY LIMITED

Appellant

and

 

THE COMMISSIONERS FOR HIS MAJESTY'S REVENUE AND CUSTOMS

Respondents

 

The Tribunal determined the appeal without a hearing pursuant to Rule 29 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009.

 


DECISION

Introduction

1.             By an application dated 20 March 2025, the Appellant ("AHT") made an application for HMRC to pay a proportion of its costs on the grounds that HMRC had acted unreasonably in the course of conducting the appeal.

2.             AHT applied for a percentage of their total costs, being the percentage which the penalty bears to the total tax and penalty in issue (i.e. 13.04% (being 15/115 as the penalty was levied at the rate of 15%)).

3.             In addition, AHT applied to waive the requirement for a costs schedule (or the time extended until after the issue of the principle of the costs award had been determined). This was on the basis that the likely level of total costs (of which 13.04% was being claimed) would be substantial (in excess of £400,000), and therefore would be appropriate to be determined by the Senior Courts Costs Judges, and not summarily.

4.             HMRC filed submissions opposing the application on 17 April 2025, and AHT filed their reply on 14 May 2025.

The law

5.             Section 29, Tribunal Courts and Enforcement Act 2007 provides that the award of costs of and incidental to all proceedings in the Tribunal shall be at the discretion of the Tribunal and subject to the FTT Rules.

6.             The relevant provisions of Rule 10, Tribunal Procedure (First-tier Tribunal)(Tax Chamber) Rules 2009, are as follows:

Orders for costs

10 (1) The Tribunal may only make an order in respect of costs (or, in Scotland, expenses)—

(a) under section 29(4) of the 2007 Act (wasted costs) and costs incurred in applying for such costs;

(b) if the Tribunal considers that a party or their representative has acted unreasonably in bringing, defending or conducting the proceedings;

[...].

(2) The Tribunal may make an order under paragraph (1) on an application or of its own initiative.

(3) A person making an application for an order under paragraph (1) must—

(a) send or deliver a written application to the Tribunal and to the person against whom it is proposed that the order be made; and

(b) send or deliver with the application a schedule of the costs or expenses claimed in sufficient detail to allow the Tribunal to undertake a summary assessment of such costs or expenses if it decides to do so.

(4) An application for an order under paragraph (1) may be made at any time during the proceedings but may not be made later than 28 days after the date on which the Tribunal sends—

(a) a decision notice recording the decision which finally disposes of all issues in the proceedings; or

(b) notice under rule 17(2) of its receipt of a withdrawal which ends the proceedings.

(5) The Tribunal may not make an order under paragraph (1) against a person (the "paying person") without first—

(a) giving that person an opportunity to make representations; and

(b) if the paying person is an individual, considering that person's financial means.

(6) The amount of costs (or, in Scotland, expenses) to be paid under an order under paragraph (1) may be ascertained by—

(a) summary assessment by the Tribunal;

(b) agreement of a specified sum by the paying person and the person entitled to receive the costs or expenses (the "receiving person"); or

(c) assessment of the whole or a specified part of the costs or expenses, including the costs or expenses of the assessment, incurred by the receiving person, if not agreed.

7.             What constitutes "unreasonable conduct" for the purposes of Rule 10 was considered by the Upper Tribunal in Distinctive Care Ltd v HMRC [2018] UKUT 155 (TCC), and upheld on appeal by the Court of Appeal ([2019] EWCA Civ 1010). In its decision, the Upper Tribunal set out at [44] to [46] the basis on which conduct is to be assessed:

[44] In Market & Opinion Research International Limited v HMRC [2015] UKUT 12 (TCC) ("MORI") at [22] and [23], the Upper Tribunal endorsed the approach set out by the FTT in that case to the question of whether a party had acted unreasonably. That approach could be summarised as follows:

(1) the threshold implied by the words "acted unreasonably" is lower than the threshold of acting "wholly unreasonably" which had previously applied in relation to proceedings before the Special Commissioners;

(2) it is possible for a single piece of conduct to amount to acting unreasonably;

(3) actions include omissions;

(4) a failure to undertake a rigorous review of the subject matter of the appeal when proceedings are commenced can amount to unreasonable conduct;

(5) there is no single way of acting reasonably, there may well be a range of reasonable conduct;

(6) the focus should be on the standard of handling the case (which we understand to refer to the proceedings before the FTT rather than to the wider dispute between the parties) rather than the quality of the original decision;

(7) the fact that an argument fails before the FTT does not necessarily mean that the party running that argument was acting unreasonably in doing so; to reach that threshold, the party must generally persist in an argument in the face of an unbeatable argument to the contrary; and

(8) the power to award costs under Rule 10 should not become a "backdoor method of costs shifting".

[45] We would wish to add one small gloss to the above summary, namely that (as suggested by the FTT in Invicta Foods Limited v HMRC [2014] UKFTT 456 (TC) at [13]), questions of reasonableness should be assessed by reference to the facts and circumstances at the time or times of the acts (or omissions) in question, and not with the benefit of hindsight.

[46] In assessing whether a party has acted unreasonably, this Tribunal in MORI went on to say this (at [49]):

"It would not, we think, be helpful for us to attempt to provide a compendious test of reasonableness for this purpose. The application of an objective test of that nature is familiar to tribunals, particularly in the Tax Chamber. It involves a value judgment which will depend upon the particular facts and circumstances of each case. It requires the tribunal to consider what a reasonable person in the position of the party concerned would reasonably have done, or not done. That is an imprecise standard, but it is the standard set by the statutory framework under which the tribunal operates. It would not be right for this Tribunal to seek to apply any more precise test or to attempt to provide a judicial gloss on the plain words of the FTT rules."

8.             I was also referred to the decisions of the First Tier Tribunal in Generator Power Ltd v HMRC [2024] UKFTT 1019 and Proctor & Gamble International Operations SA v HMRC [2022] UKFTT 299, but I do not consider that they add very much to the Upper Tribunal's decision in Distinctive Care, (as endorsed by the Court of Appeal).

9.             The corresponding provision in the Rules of the Property Chamber were considered by the Upper Tribunal (Lands Chamber) in Willow Court Management Company (1985) v Alexander [2016] UKUT 290 (LC):

[24] An assessment of whether behaviour is unreasonable requires a value judgment on which views might differ but the standard of behaviour expected of parties in tribunal proceedings ought not to be set at an unrealistic level. We see no reason to depart from the guidance given in Ridehalgh at 232E, despite the slightly different context. "Unreasonable" conduct includes conduct which is vexatious, and designed to harass the other side rather than advance the resolution of the case. It is not enough that the conduct leads in the event to an unsuccessful outcome. The test may be expressed in different ways. Would a reasonable person in the position of the party have conducted themselves in the manner complained of? Or Sir Thomas Bingham's "acid test": is there a reasonable explanation for the conduct complained of?

Background Facts

10.         This application was made at the invitation of the Tribunal, and the context for the application is set out in paragraphs [12] to [16] of the Tribunal's decision:

12. At an early stage on the first day of the hearing, Mr Rivett made an application to admit into evidence a copy of an email dated 20 June 2007 to Dr Farjo from a partner at AHT's then accountants, UHY Hacker Young. The email reported on a telephone call between the partner and an HMRC officer who was a policy advisor on social reliefs. The telephone call concerned the extent of the VAT exemption for medical services. The email reported that the officer had confirmed that HMRC adopt a wide interpretation to the definition of medical and surgical treatment in registered hospitals and clinics, and that (apart from beauty procedures using lasers and IPL machines) "the exemption from VAT remained appropriate irrespective of the purpose of the treatment". Mr Millington did not object and we gave our consent to the admission of this email exchange into evidence.

13. Mr Rivett, rightly, has not suggested that AHT has any legitimate expectation to hold HMRC to the statements made in this email exchange. The information given by UHY Hacker Young to HMRC does not even begin to meet the requirements set out in R v Inland Revenue Commissioners, ex parte MFK Underwriting Agencies Ltd [1990] 1 WLR 1545, and in any event, we do not have jurisdiction to determine questions of legitimate expectation in the circumstances of this appeal. However, the email exchange does go to the issue of whether AHT had a reasonable excuse for its failure to register for VAT, given that the professional advice it received was that its services were VAT exempt.

14. During the course of the second day of the hearing, we asked Mr Millington to consider with his clients whether they wished to pursue the penalty assessment, and to revert back to us at the commencement of the hearing on the following (third) day. Mr Millington was unable to obtain instructions on this issue overnight, nor over the lunch adjournment on day three. At the end of day three he informed us that HMRC's position had not changed since the start of the hearing - a penalty assessment had been issued, the relevant evidence would need to be heard, and the Tribunal would need to adjudicate on the issue.

15. We had directed that the hearing should commence on day four at 09:30 – starting with the evidence of Mr Olatoye. The hearing in fact had to start later than 09:30 because Mr Olatoye did not arrive at the hearing centre in sufficient time to clear security before the time the hearing was due to commence. When the hearing commenced, Mr Rivett told us that at 09:28 he had asked whether Mr Millington had received instructions on this issue, and was told that he had not. Only after Mr Olatoye arrived (late) in the court room was Mr Millington able to confirm that HMRC had decided not to pursue the assessment for penalties, and the penalty assessment would be withdrawn. Mr Rivett noted that because of the lateness of the withdrawal, he had had to spend time the previous evening preparing to cross-examine Mr Olatoye in relation to the penalty assessment.

16. We invite AHT to consider whether it wishes to make an application for costs incurred in consequence of the failure of HMRC to notify its intention to withdraw the penalty assessment until after the commencement of the hearing on day four, and to make submissions on whether HMRC's failure to notify the withdrawal until minutes before Mr Olatoye was due to give evidence constitutes unreasonable conduct for the purposes of Rule 10(1)(b) of the Tribunal's procedure rules. We draw the attention of the parties to the requirements of Rule 2(4)(b) which requires parties to co-operate  with the Tribunal generally. As regards the procedure to be adopted for any application for costs, we draw the attention of the parties to paragraphs (3) and (4) of Rule 10, and direct that the time limit in paragraph (4) shall be varied to read 28 days after the date on which this decision notice is released.

11.         By way of amplification, of the description given in the decision, I made the following request of Mr Millington following the conclusion of Dr Farjo's oral evidence on day 2 of the hearing:

JUDGE ALEKSANDER: [...] in terms of reasonable excuse and mitigation, if the taxpayer took reasonable care in seeking advice as to their liability, maybe that advice was wrong, but it was obtained from what was a competent professional having given full disclosure, that would be a strong indication that they have a reasonable excuse and acted as a prudent and reasonable taxpayer. One of the points I am going to suggest you might want to consider overnight with your clients is in the light of Dr. Farjo's evidence, whether you want to pursue the penalties. 

MR. MILLINGTON: Understood.

12.         During the course of day 3, I asked Mr Millington whether he had been able to take instructions, and he reported that a conference had been arranged over the lunch adjournment. In the afternoon Mr Millington reported that he had not been able to obtain instructions on the issue.

13.         It is appropriate to set out the exchange of remarks made at the commencement of the hearing on day four in full:

MR. MILLINGTON:  Yes, before calling Mr. Olatoye, the Commissioners have considered the tribunal's position relating to the factual issue and reasonable excuse.  The Commissioners will not invite the tribunal to make a determination on the penalty issue and that penalty will be withdrawn in the light of the observation in the factual evidence. I do not intend to dwell on this issue, but if I may at this stage make the following submissions, the Commissioners have been subject to implicit and perhaps latterly explicit criticism for the position this week in respect of the penalty following questions about the factual evidence.

JUDGE ALEKSANDER:  Yes.

MR. MILLINGTON:  The penalty was issued a number of years ago.  It is the appellant's responsibility to demonstrate that there is a reasonable excuse, either to the satisfaction of the Commissioners or the tribunal.  The Commissioners, in their skeleton argument, were perfectly entitled to ask the relevance of the document addressed to Hacker Young and how that related to a reasonable excuse. It was not until Friday of last week that the Commissioners were sent an e-mail which placed that letter in context.  Judge, you will remember that I did not seek to prevent that document from going before the  tribunal.

JUDGE ALEKSANDER:  Yes.

MR. MILLINGTON:  Mindful, of course, that the tribunal would want all available evidence, particularly in the context of a penalty decision and the effect that that would have on the taxpayer.  You expressed some views on the panel's view of the reasonable excuse having heard the evidence of Dr. Farjo on  that issue.  Since then, the Commissioners have considered their position, but it is unfortunate that the document that explained the relevance of a letter in the bundle was produced so late in the day.  To that extent, whilst the Commissioners have now withdrawn the penalty in light of the tribunal's comments on the evidence it has heard, in my submission, any criticism of the Commissioners for the issuing of the penalty and proceeding with this penalty to the tribunal must be seen in light of the late disclosure of that evidence.  So, the decision has now been taken, and appropriate persons have been  consulted.

JUDGE ALEKSANDER:  Thank you. Is there anything you want to say in response to that?

MR. RIVETT:  I hesitate to be ungracious, sir, but I am afraid that just in fairness to the number of people who have been up all night, all week, exhausted, stressed, frightened about the future of their business and the context in which this has been answered, and I mean this with no disrespect to my learned friend, he is counsel, he is not his clients, at 28 minutes after nine this morning, so two minutes before this officer, who I have been busily preparing to cross-examine, using my time in a very pressured court week to prepare for the cross-examination, I asked my learned friend, "Can you tell me what the position is on this penalty?"  My learned friend, as is his position, said, "I cannot; I do not have instructions on that point."  His witness turned up ten  minutes late depriving us of yet more time this morning.

JUDGE ALEKSANDER:  I understand that that may be due to the slowness of the security.

MR. RIVETT:  Everybody gets here early to accommodate that.  He was ten minutes late to give evidence to this court.  I asked  my learned friend.  It was clear who was responsible for the lateness of the sitting this morning.  Suddenly, the witness appeared and, lo and behold, the penalty was withdrawn. I think, if I may say so, I accept the submissions that are made about the issuance of the penalty, but it is very, very hard to escape the inference that what has been going on and  the refusal to answer the very clear question that this court asked HMRC, with the decision-makers in the room, two days ago, not to withdraw this penalty two days ago is some sort gamesmanship.  With respect, sir, it is just not appropriate in these circumstances. A clear question was asked two days ago.  I am afraid the explanation that my learned friend has given as to why they are willing to withdraw it, in the face of the letter of  Friday, which explains his concession, what it does not go anywhere near is meeting why this tribunal was not provided with an answer before I was due to be cross-examining this witness.

JUDGE ALEKSANDER:  I do not propose to take further submissions on this point now.  What applications are made by parties once we have reached a decision, we will deal with.

14.         I note that the UHY Hacker Young email of 20 June 2007 was not included in AHT's list of documents nor was it exhibited to any witness statement, which is why Mr Rivett, very properly, applied to the Tribunal to admit the email as evidence on the morning of the first day of the hearing. It had been copied to HMRC's solicitors on Friday 23 February 2024 (in HMRC's submissions they state that it was received "after hours"). In other words, because the hearing commended on Monday 26 February 2024. HMRC were not able to give consideration to this evidence until immediately preceding the commencement of the hearing.

Submissions of the parties

15.         AHT submit that it was unreasonable for HMRC to fail to provide instructions to their representatives to withdraw the penalty assessment until the arrival of Mr Olatoye at the hearing immediately before he was due to give evidence. They submit that this was a failure promptly to act, it having become clear that the penalty assessment could no longer properly be defended and that it was "doomed to fail". Promptness is a fact-sensitive question as with all questions of unreasonable behaviour. In this case, given that (i) the hearing was continuing (and time was short such that any reduction in the scope of the issues could have helped the hearing to avoid going part-heard), (ii) my request to HMRC's counsel to obtain instructions before the beginning of the third day, (iii) the fact the assessment was to penalties (with, AHT says, the inevitable seriousness of the context of criticism of the behaviour of doctors in relation to their practices), HMRC's actions cannot be seen as prompt.  This, AHT submits, is unreasonable behaviour.

16.         AHT submits that a proportionate order is appropriate as it should reflect the relative importance (in monetary terms) of the penalty assessment to the total money at stake in the litigation - even though this underrepresents the wider significance of a penalty with the implications of at least a degree of misconduct compared to a technical dispute about the scope of legislation.

17.         HMRC submit that the witness evidence filed on behalf of AHT made only cursory mention of advice received in 1993 as the basis for their "reasonable excuse", and HMRC's skeleton argument states that the documentation had not been properly explained in evidence. The UHY Hacker Young email, they say, was not produced until "after hours" on the working day immediately preceding the commencement of the hearing. Given the paucity of evidence relevant to this issue in the statement of Dr Farjo, HMRC submit that they were obliged to explore the advice received by the AHT in the cross-examination of Dr Farjo.

18.         HMRC submit that notwithstanding the provisional view implicit in my request that they reconsider the penalty decision in light of Dr Farjo's evidence, it cannot be said that their defence of the penalty appeal was "doomed to fail". A determination that a reasonable excuse exists involves a careful consideration of all the circumstances of the case, and HMRC were entitled to consider all the evidence (oral and documentary) in assessing the merits of continuing to resist the appeal.

19.         HMRC contrast the circumstances in this case with the circumstances in Generator Power, where new evidence was produced by the appellant at the hearing, and HMRC were given 28 days to consider that evidence. In the circumstances in this appeal, HMRC are criticised for withdrawing the penalty less than 48 hours after I had given an indication that they should consider whether they wished to pursue penalties.

20.         AHT have also made allegations that the decision of HMRC to notify the withdrawal of the penalties only on the morning of the fourth day may have been motivated by (to put it at its mildest) litigation tactics. These allegations are strenuously denied by HMRC. There is no evidence to support any of these allegations, and I have not taken them into account in reaching my decision.

Discussion

21.         I agree with HMRC that the evidence included in Dr Farjo's witness statement relating to the existence of a reasonable excuse was, at best, cursory. I also agree that, in the light of the UHY Hacker Young email, it was reasonable for HMRC to cross-examine Dr Farjo about it. However, once that cross-examination had been concluded, it was very clear that AHT had been neither careless nor negligent in their decision to treat supplies of hair transplant services as exempt, and that they had a reasonable excuse for their actions. I find that with effect from the conclusion of the cross-examination of Dr Farjo, it was obvious that AHT had a reasonable excuse for treating their supplies of hair transplantation services as exempt. I acknowledge that HMRC were entitled to a reasonable period of time after the conclusion of Dr Farjo's cross-examination in which to consider whether to continue to pursue the penalty. However, after the expiry of that reasonable period, I find that it was unreasonable for HMRC to continue to pursue the penalty assessment.

22.         I consider that the circumstances of this appeal are very different from the circumstances in Generator Power. In Generator Power there was a substantial amount of new evidence, described by counsel for the appellants as including printouts from the internet, and "pages and pages of people claiming to offer a 24/7 service". HMRC subsequently described the new evidence as including: contracts, market analysis, further witness evidence and new oral evidence. The volume of new documentary evidence produced in Generator Power was clearly very substantial indeed. In contrast, in this case, the new evidence was a short, and easily understood, email, on which Dr Farjo was cross-examined. I find that it would be but a few minutes of work to assess that evidence and reach a conclusion that it was no longer sustainable nor reasonable for HMRC to continue to pursue penalties.

23.         HMRC's decision maker was Mr Olatoye, and he was the witness produced by HMRC to justify the imposition of the penalty. Mr Olatoye is a senior officer of HMRC, was present throughout the hearing. Mr Olatoye was aware of the UHY Hacker Young email at least from the commencement of day 1 of the hearing, and he heard Mr Farjo's oral evidence. I appreciate that Mr Olatoye would have wanted to take legal advice from HMRC's counsel, and may have also wanted to consult colleagues. I find that this could easily have been done after the conclusion of the hearing on day 2, or during the lunch adjournment on day 3. No satisfactory explanation has been given as to exactly when the decision to withdraw penalties was made, and why the decision was not communicated to AHT until after the commencement of the hearing on day 4.

24.         I find that HMRC's conduct in continuing to pursue the penalty assessment became unreasonable following the conclusion of the lunch adjournment on day 3, and the failure of Mr Olatoye (or the failure of his colleagues) to withdraw the penalty and communicate that decision to AHT until after the commencement of the hearing on day 4 amounted to unreasonable conduct for the purposes of Rule 10.

25.         I find that it was only following the conclusion of Dr Farjo's oral evidence on day 2 that HMRC were in possession of evidence demonstrating that AHT had a reasonable excuse for their conduct. HMRC would require a reasonable period of time following that point in which to take stock of the evidence and make a decision. I have found that this period would have expired at the conclusion of the lunch adjournment on day 3.

26.         In these circumstances, I find that it would be disproportionate to award costs on a percentage basis - namely 13.04% of Dr Farjo's total costs. I find that any award of costs must be restricted to costs incurred by AHT relating to the penalty assessment after the lunch adjournment on day 3 - and in particular (but not necessarily limited to) the time taken by counsel for AHT to prepare for the cross-examination of Mr Olatoye after the conclusion of the hearing on day 3.

27.         AHT submit that taking an approach on "costs from a certain date" operates unfairly in circumstances where an appellant has agreed a single composite fee for a hearing rather than being charged on an hourly basis - particularly if the fee has been incurred prior to the hearing. In the case of this appeal, AHT's counsel were paid a brief fee (without "refreshers" - i.e. charges based on a hearing lasting more than a day) which was incurred prior to the hearing, and they did not charge for the resumed hearing. Whilst I appreciate the difficulty faced in these circumstances, counsel (and those instructing them) in agreeing a fixed fee must have estimated the likely time needed to be spent on preparation and for the anticipated four listed days for the hearing. So it should be possible to calculate an imputed hourly rate. Alternatively, if AHT's counsel and other advisors kept time records, it should be possible to determine an effective hourly rate for the period from when the fixed fee took effect until the conclusion of the fourth day of the hearing. No doubt other reasonable methods of allocating costs to the relevant time frame may be available. As the hearing was originally listed for four days (and counsel did not charge for the additional day) I consider that any method for the allocation of costs should ignore the final day of the hearing.

28.         AHT have applied that the requirement to file a schedule of costs should be waived on the grounds that preparation of a schedule of costs would be inappropriate, as such costs would be assessed by the Senior Courts Costs Office, and would not be assessed summarily. I appreciate that if costs were to be awarded as a percentage of the total costs incurred by AHT, it might be arguable that such costs ought to be assessed by a specialist Costs Judge. In any event, given that the basis on which costs should be awarded (either a percentage of a fixed fee or "from a certain date") was in dispute, a schedule of costs could not usefully be prepared until after this decision is released. But, in the light of my decision that costs should be limited to those incurred after the lunch adjournment on day 3, I consider that it is possible that they could now be assessed summarily.

Disposition

29.         I direct that HMRC pay to AHT the costs incurred by AHT following the lunch adjournment on 28 February 2024 which relate to the penalty assessment, and that costs be assessed on the standard basis.

30.         If the parties are unable to agree the amount of costs, AHT are directed to file with the Tribunal (and copy to HMRC) no later than 28 days after the date of release of this decision a schedule of the costs or expenses claimed in sufficient detail to allow the Tribunal to undertake a summary assessment of such costs or expenses if it decides to do so. HMRC may file their representations on the schedule of costs no later than 14 days after the schedule of costs is filed.

Right to apply for permission to appeal

31.         This document contains full findings of fact and reasons for the decision.  Any party dissatisfied with this decision has a right to apply for permission to appeal against it pursuant to Rule 39 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009.  The application must be received by this Tribunal not later than 56 days after this decision is sent to that party.  The parties are referred to "Guidance to accompany a Decision from the First-tier Tribunal (Tax Chamber)" which accompanies and forms part of this decision notice.

 

NICHOLAS ALEKSANDER

TRIBUNAL JUDGE

 

Release date: 29th MAY 2025

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