Legal Watch: Professional Indemnity April 2014 – Issue: 001
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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