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Lafarge convictions: a landmark moment in corporate criminal accountability
Louise Hodges
This quarterly civil fraud update provides a summary of reported decisions handed down in the courts of England and Wales in the period of January - March 2026.
Many people mistakenly believe that once they've established residency outside the UK, HMRC's authority over their tax affairs ceases to exist. However, HMRC retains the power to examine historical matters stretching back up to two decades in the most serious cases, and UK-situated assets remain within their jurisdiction regardless of where the owner physically resides.
This quarterly civil fraud update provides a summary of reported decisions handed down in the courts of England and Wales in the period of October - December 2025.
In 2025, two High Court rulings, Apollo XI Ltd v Nexedge Markets Ltd and J&J Snack Foods Corp & ICEE Corp v Ralph Peters & Sons Ltd highlighted the strict nature of the duty of full and frank disclosure in without notice applications.
In both cases, the court discharged freezing injunctions after finding that the applicants had failed to meet the requisite standard of candour and fair presentation. These decisions serve as a clear reminder that when seeking urgent relief without notifying the other party, applicants must present all material facts - including those that may undermine their case, and ensure the court receives a balanced and accurate account.
Where the identity of a person or group of people responsible for a fraud is not known, the courts have recognised that it may be appropriate in certain circumstances to allow a claimant to issue proceedings and obtain an injunction (both interim and final) against such individuals. These injunctions are referred to as “persons unknown injunctions” and they have become increasingly prominent in recent years.
Louise Hodges
Jemma Garside
Lord Carter of Haslemere CB
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