Sadaf Ijaz v Solicitors Regulation Authority Limited

In a statutory appeal, an Appellant’s Notice must identify the decision challenged and include grounds of appeal. If the court office accepts the filed materials as an appeal within time, the appeal is treated as brought within time despite an omission. Late grounds nevertheless require permission, and without permission the appellant has no grounds on which to rely. VAT registration does not make VAT on non-taxable regulatory legal work recoverable as input tax. A disciplinary tribunal has a substantial discretion over privacy applications, subject to open justice. A factual error is immaterial where the tribunal’s decision, assessed as a whole, remains justified.

This was a statutory appeal under the Solicitors Act 1974 against a decision of the Solicitors Disciplinary Tribunal dated 22 October 2025. The Tribunal had dismissed the appellant’s challenge to a written rebuke imposed by the SRA Adjudicator and Adjudication Panel and had ordered her to pay the SRA’s costs. The appellant filed an Appellant’s Notice within 21 days but without grounds of appeal. She filed proposed grounds over four months later and never sought permission to rely on them. The central issues were whether the appeal had been brought in time, whether the late grounds could be relied on, and whether the proposed grounds concerning VAT-inclusive costs, privacy applications and an alleged factual error had merit.

Appeal dismissed. The SRA’s preliminary objection that the appeal was time-barred was rejected, but no grounds of appeal were properly before the court.

1. Section 44E of the Solicitors Act 1974 provides the statutory appeal route. The 21-day period in CPR 52.12(2)(b), identified in Taylor v SRA [2019] EWHC 201 (Admin), applied. The Appellant’s Notice was filed on the twenty-first day. Although it contained no grounds, the court office accepted the filed materials as constituting an appeal, so the appeal had been brought within time.
2. Grounds of appeal are an essential part of a properly completed Appellant’s Notice, rather than an ancillary requirement. The scope of Siniakovich v Hassan-Soudey & Ors [2026] EWCA Civ 215 was confined to cases involving a fully completed claim form or Appellant’s Notice. Eskander v GMC [2026] EWCA Civ 372 supported the distinction between an essential document and an ancillary omission. Acceptance of the notice did not permit the appellant to file grounds whenever she chose. Permission was required to rely on the late grounds, and none had been sought.
3. Even if the proposed grounds had been admitted, the VAT ground failed. VAT registration did not establish that the SRA could recover VAT paid on all legal services. Professional regulation and enforcement were not taxable activities, so the SRA could not recover the relevant input tax. Under CPR Practice Direction 44, paragraph 2.3, VAT was therefore properly included in the costs claim.
4. The SDT had a substantial discretion to manage its proceedings, subject to close regard for open justice. There was no realistic connection between alleged threats and public access to the hearing, and no evidence of disruption. The anonymity application was not pursued after an assurance concerning publication of the appellant’s address.
5. The SDT was required to assess the Adjudication Panel’s decision as a whole. Even assuming that the appellant had sought a stay of the 2019 costs order, her continued non-payment after the appeal ended, together with delayed payment of the 2022 costs order, meant that any factual error was immaterial. The SDT was entitled to uphold the rebuke.

1. High Court (Administrative Court): The statutory appeal was dismissed. The court held that the appeal had been filed in time but that no grounds could be relied on without permission. It also rejected the proposed grounds on their merits.
2. Solicitors Disciplinary Tribunal: On 22 October 2025, the Tribunal dismissed the appeal against the written rebuke, refused the application to admit fresh evidence, and ordered the appellant to pay the SRA’s costs.
3. SRA Adjudicator and Adjudication Panel: The Adjudicator imposed the written rebuke under the Solicitors Act 1974. The Adjudication Panel upheld that decision on review.