Wonop ApS v Simon Jagger & Ors

Registration of a notice under paragraph 84(1) of Schedule B1 to the Insolvency Act 1986 automatically terminates the administrator’s appointment under paragraph 84(4). The termination operates even where the court has appointed replacement administrators or extended the administration before registration.

Paragraph 95 addresses the identity of the office-holder and presupposes that the office itself continues. It does not displace the self-executing effect of paragraph 84(4). The statutory scheme favours a simple, swift and final exit where the company has no property available for distribution.

FAI Realisations 2024 Limited entered administration in January 2024. Wonop ApS, a creditor, applied to remove the joint administrators, postpone their discharge and appoint replacements. Before the substantive hearing, the administrators filed a notice under paragraph 84 of Schedule B1 to the Insolvency Act 1986 moving the company towards dissolution.

Rajah J subsequently removed the administrators, appointed replacements on a restricted basis and extended the administration. Companies House registered the notice on 26 January 2026. The central issue was whether registration nevertheless brought the administration and the administrators’ appointments to an end under paragraph 84(4).

1. Application determined. The court held that the administration ended on 26 January 2026 when Companies House registered the notice under paragraph 84. The administrators’ appointments therefore ceased by operation of paragraph 84(4) of Schedule B1.
2. Statutory interpretation is purposive and contextual. The statutory words remain the primary source of meaning, read in the context of the provision, the relevant group of provisions and the statutory scheme as a whole. The statutory purpose of the administration reforms was to provide clearer, more predictable and efficient exit routes.
3. Paragraph 84(4) is a self-executing provision. Registration of a properly filed notice terminates the administrator’s office. The court applied the reasoning in E Squared Ltd and Re Globespan Airways Ltd, which emphasised the significance of registration and the short period during which the Registrar may check the notice.
4. Paragraph 95 is concerned with replacing an office-holder. It presupposes the continued existence of the office and does not create an exception to paragraph 84(4). Schedule B1 draws no distinction between a case in which replacement administrators have been appointed or the administration extended and one in which those steps have not occurred.
5. The order made by Rajah J did not disapply paragraph 84. The issue and statutory effect had not been addressed at that hearing, and the order could not prevent the statutory termination. The court invited the applicant to submit an order for approval.

This was a first-instance decision. The judgment records that Rajah J made interim orders on 21 January 2026 removing the joint administrators, appointing replacement administrators on a restricted basis and extending the administration pending the substantive hearing.