Restructuring & Insolvency analysis: In an application for an extended civil restraint order (ECRO) or limited civil restraint order (LCRO), the court granted relief against Mr Anwer—a litigant in person that had brought a total of seven applications which were totally without merit. Central Bridging Loans Ltd (CBL) had issued a statutory demand against Mr Anwer in respect of sums due under a loan. Mr Anwer applied to have the statutory demand set aside, and also brought proceedings against CBL in the County Court, both on the alleged basis that CBL had intentionally and fraudulently delayed the sale of his property, against which the loan was secured, to increase the interest payable to them. The court held that CBL had demonstrated the necessary degree of persistence to warrant the making of an ECRO. The case should act as a warning for individuals who wish to set aside statutory demands and issue more than one application to do so—unless the basis for a second application is different, it might be dismissed as totally without merit and become a factor justifying the imposition of an ECRO. Written by Karl Anderson, barrister, at 4 Stone Buildings.

This Practice Note on multiple tortfeasors considers the specific issues with regard to liability where a tortious claim involves more than one defendant/prospective defendant, including same damage, same act (joint tortfeasor) concept, when directors may be liable and concepts of accessory liability in tort and knowledge, and the practical considerations of pleading such claims or drafting an agreement to settle such claims. For guidance generally on multi-party liability issues, see Practice Notes: • Vicarious liability and multi-party torts • Joint, several, and joint and several liability • Contribution claims under Civil Liability (Contribution) Act 1978—entitlement, scope and ‘same damage’ • Settling disputes—claims involving three or more parties Multiple tortfeasors—the different categories of tortfeasor Where there is more than one tortfeasor (party responsible for a tort) they can fall into one of the following categories: • joint tortfeasors: the parties are responsible for the same damage through the same tortious act • several tortfeasors: the parties are responsible for causing the same damage • several tortfeasors: the parties are responsible for causing different damage Joint tortfeasors—same damage,

An action to determine the rights of parties to a fund or property in dispute and to release the holder of the fund from any claim.

The conventional method used to calculate future losses by converting continuing losses to a single lump sum is to multiply an annual loss (the multiplicand) by a multiplier. This is the approach commonly applied to future loss claims using multiplier figures from the Ogden tables.

Multiplicity of actions describes a situation where substantially the same dispute is pursued through two or more sets of legal proceedings, often in different courts or between overlapping parties. It commonly arises where parallel claims, duplicative proceedings or fragmented litigation risk inconsistent judgments, wasted costs and inefficient use of court resources.In the UK and Ireland, “multiplicity of actions” is generally a descriptive expression rather than a defined statutory term. It appears frequently in case law and procedural argument, particularly in applications for case management stays, striking out, abuse of process, forum non conveniens and anti‑suit injunctions.Courts in England & Wales, Scotland, Northern Ireland and Ireland share a common objective of avoiding multiplicity of actions. Judges may respond by: staying one set of proceedings; ordering consolidation or transfer; striking out as an abuse of process; or giving directions to coordinate related cases.In cross‑border and commercial litigation, addressing multiplicity of actions is crucial to risk management, controlling litigation costs and reducing the danger of conflicting decisions, especially where parallel proceedings are on foot in another UK jurisdiction, Ireland, or overseas courts.

is the figure representing the number of future years by which the annual loss (‘the multiplicand’) is multiplied to reflect the period over which the loss is likely to be suffered.

NOTE: On 2 December 2024, the Lord Chancellor announced that the discount rate would change to positive 0.5%. The positive 0.5% discount rate is effective from 11 January 2025. Schedule A1 to the Damages Act 1996 (DA 1996) provides that each subsequent review must be started within the five-year period following the last review. For these purposes, a review is concluded when the Lord Chancellor makes the determination as to the rate. This Practice Note outlines the conventional method of converting ongoing losses to a single lump sum by multiplying an annual loss, assessed at the time of settlement or court award, by a multiplier. This is the multiplier/multiplicand approach and is used in the vast majority of claims for future losses. The Practice Note also considers in further detail how the multiplicand is calculated and explains how the Ogden Tables are used to assess the appropriate multiplier to apply in a case. NOTE: The 8th edition of the Ogden Tables (updated in August 2022) can be accessed here.

Also known as 'wireless cable', this is a one-way, domestic public radio service broadcast on microwave frequencies from a fixed station that transmits (usually in an omnidirectional pattern) to multiple receiving facilities located at fixed points determined by the subscriber’s location.

CASE HUB ARCHIVED–this archived case hub reflects the position at the date of the decision of 24 May 2013 and the ending of the enforcement proceedings on 29 October 2014; it is no longer maintained. See further, timeline and commentary. Case facts Outline European Commission merger investigation into the planned merger of Munksjo and part of Ahlstrom’s business to form ‘NewCo’ (Case M.6576). The Commission cleared the transaction subject to commitments on 24/05/2013. Enforcement proceedings relating to the provision of misleading information were launched by the Commission but dropped on 29/10/2014. Latest developments The Commission cleared the merger subject to commitments on 24 May 2013. The commitment accepted is the divestment of Ahlstrom’s abrasive paper backings and PRIP business located in Osnabrück, Germany. Ahlstrom will retain one paper machine on the site though that is not used for the production of either abrasive paper backings or PRIP. Certain utilities at the site will be transferred to a new joint venture controlled jointly by Ahlstrom and the new owner of the divested assets. On 25 February 2014, the Commission

A sale with mark-up or profit.

STOP PRESS: On 8 October 2026, the Loan Market Association (LMA) published a User Guide and a set of model form Murabaha Facility Transfer Agreements to facilitate the transfer of an existing participation in a Murabaha finance structure. The documentation includes agreements relating to the transfer of participations, commodity purchase and sale arrangements and syndication settlement. These documents are available to members of the LMA on its website. A basic Murabaha and a commodity Murabaha arrangement can both be structured to facilitate a single transaction, or to operate on a revolving basis so that several transactions can be entered into under the same facility. Both types of documentation will provide the same basic mechanics for entering into transactions. However, for a revolving facility, the customer (the Customer) and the finance provider (an Islamic financial institution (IFI)) will usually enter into a master agreement that will govern the basic terms of their future transactions, with the particular terms of a given transaction identified at the time of such transaction. This

This Practice Note on Islamic finance and tax outlines how a Murabaha works as a form of financing, the UK corporation tax and withholding tax issues that apply to a Murabaha that qualifies as a purchase and resale arrangement under the UK alternative finance arrangement rules. It also considers certain stamp taxes and VAT issues relevant to a Murabaha. Shari’a compliant financing arrangements (also known as Islamic financing arrangements) can take a number of forms. The UK has introduced specific provisions known as the alternative finance arrangement rules to deal with the direct tax treatment of certain forms of Shari’a financing. The UK alternative finance arrangement rules are intended to allow Shari’a compliant financing arrangements to be treated for UK direct tax purposes in the same way as if they were a conventional loan. This treatment is dependent on the financing arrangements satisfying the relevant provisions in the legislation applicable to alternative finance arrangements. The rules currently cover five different types of financing arrangements. Some areas of tax legislation,