Litigant Record IV 

Litigant Record IV – Index (Live Record Edition)

This fourth record is not a retrospective. It is a live forensic account of ongoing harm, unresolved safeguarding risks, and institutional choreography designed to contain, deflect, and delay. The following index maps the current status of each regulator, the emotional and procedural fallout, and the demands for reform that must now be heard.

I. The Solicitors Regulation Authority (SRA)

Containment by Design

• The Gatekeeper’s Delay (40–45 day wait as active harm)
• Strategic Silence → Capsule I.2 (Still unaddressed)
• Case Study: Axiom Ince — £60 Million Vanished, 1,400 Jobs Lost
  • Includes Deflection by Design – When Oversight Protects the System, Not the Public
• The Architecture of Avoidance (Still being performed)
• Regulatory Performance vs Protection (Measured in real time)

Visibility Without Remedy

When Oversight Performs, But Doesn’t Protect

• Visibility Without Engagement (No reply, no remedy)
• The Gatekeeper’s Delay — A Forensic Record of Strategic Pausing

What the Regulator Did — Endorsement by Minimisation

• When the Ruling Wasn’t Enough — The Attempted Re-entry After Judicial Refusal
• Why I Stepped Back — When Containment Became Dangerous
• When the Regulator Reframed the Breach — The SRA’s Defence of the Indefensible

Structural Silence

• Visibility Without Engagement – A Forensic Record of Performed Access
• Service Matter as Deflection – A Forensic Record of Misclassification
• Decision-Maker Index → SRA Edition (Who holds the file now)

Live Record Edition – Page 2 Index

 II. - The Legal Ombudsman

 The Loop of Non-Remedy

Capsule 1

Welcome to the Loop – When Remedy Is Promised but Never Delivered

Capsule 2

Complaint Passed to Independent Reviewer (Status: Unverified)

Capsule 3

“Likely Aware” as a Script – Used to Void the Complaint, Not Test the Evidence

Capsule 4

Safeguarding Fallout – Ongoing, Unresolved

Capsule 5

Timeline of Exclusion – Still Unfolding, Not Historic

Capsule 6

Decision-Maker Index → LO Edition (Who Is Responsible Now)

Capsule 7

The Legal Ombudsman Is Not Functioning as an Independent Body

Capsule 8

Safeguarding Fallout – Silent Conflicts, Unacknowledged Risk

Capsule 9

Who Benefits from the Silence? – Solicitor-Led Containment and Systemic Evasion

Capsule 10

Regulatory Containment – When Misconduct Is Reframed as a Proposal

Capsule 11

Audit the Harm – A Call to Reopen Every Silenced Complaint

Capsule 12

Who Can Be Trusted to Audit the Harm – Mapping Structural Independence

Capsule 13

Who Trains the Gatekeepers? – When Oversight Is Unqualified and Underexamined

Capsule 14.1

The Architecture of Endorsement – When Silence Is Signed Off

Capsule 14.2

Who Signed Off on Harm – The Guardians of Regulatory Evasion

Capsule 14.3

The Performance of Oversight – When Fairness Is Rehearsed, Not Delivered

III. Emotional and Safeguarding Fallout – Page 3 Index

The Cost of Containment

• Impact on Family (Ongoing, not resolved)
• Impact on Individual (Ongoing, not resolved)
• Visibility Without Engagement (No response in real time)
• Who Benefits from the Silence? (Public interest argument)

Recommendations and Demands for Reform

• What Must Change (Based on trilogy + Litigant Record IV)
• Who Must Change (SRA, LO, PHSO, Parliament)
• The Next Steps (My Actions, My Expectations)

The Parliamentary and Health Service Ombudsman (PHSO)

The Final Filter

• No Remedy Left Within the System (LO refusal confirmed; JR inaccessible). 
• Why This Step Is Required (No direct access for Litigants in Person)
• Decision-Maker Index → PHSO Edition (Who must answer next)
• MP Referral Initiated awaiting engagement)

I. The Solicitors Regulation Authority (SRA)

 Containment by Design

The Gatekeeper’s Delay (40–45 day wait as active harm)

The Solicitors Regulation Authority (SRA) was created following the 2004 Clementi Report, which recommended separating legal regulation from professional representation. Before this, the Law Society both represented and regulated solicitors—raising concerns about fairness and accountability.

To address this, Parliament passed the Legal Services Act in 2007. The SRA was established as the regulatory arm of the Law Society, tasked with protecting the public and enforcing ethical standards. It began operating on 29 January 2007 and now oversees over 200,000 solicitors and 11,000+ firms across England and Wales.

In theory, the SRA exists to:

• Regulate solicitors and law firms in England and Wales
• Enforce ethical standards and professional conduct
• Investigate misconduct and impose sanctions
• Maintain public trust in legal services

But as Litigant Record IV documents, its design also enables containment—especially for Litigants in Person. The current 40–45-day delay in responding to complaints is not a neutral backlog. It is a form of strategic harm. It allows misconduct to remain unaddressed, safeguarding risks to persist, and emotional fallout to deepen—all while the regulator remains visibly present but procedurally absent. 

This capsule documents how procedural delay functions as a containment mechanism—not a backlog.

This record does not simply challenge decisions. It exposes the architecture that protects them.

Silence as Strategy (Capsule I.2)

The SRA’s structure appears robust: a board with oversight subcommittees, a Chief Executive (Paul Philip, as of 2025), and a senior management team tasked with operational delivery. Its mandate is to protect the public, uphold legal standards, and maintain trust in the profession. It regulates over 200,000 solicitors and 11,000+ firms across England and Wales.

Its core functions include:

• Setting Standards: via the SRA Handbook, Code of Conduct, and Solicitors’ Accounts Rules
• Routine Audits and Spot Checks: designed to catch surface-level breaches, but not client harm
• Investigating Misconduct: through triage, case assessment, and formal inquiry
• Enforcement & Sanctions: ranging from warnings to SDT referrals

But here’s the contradiction:

These mechanisms are visible—but not engaged. Strategic silence begins at triage, where complaints are often reclassified as “service matters” and redirected to the Legal Ombudsman. Even when retained, cases may be closed without investigation if deemed low risk or lacking evidence—often without meaningful communication.

Routine audits focus on paperwork. Spot checks are designed to catch anomalies in reporting—not misconduct that harms clients. For Litigants in Person, this means a firm can pass inspection while mishandling a case, because the audit isn’t built to detect that kind of harm.

This capsule documents how the SRA’s silence is procedural, not passive—beginning at triage and embedded in its regulatory design.

Between July and October 2024, I submitted contradiction-proof communications. The SRA acknowledged receipt—but did not engage. No safeguarding referral. No substantive reply. No remedy. This silence is not absence. It is containment by omission.

Case Study: Axiom Ince

£60 Million Vanished, 1,400 Jobs Lost

In 2023, Axiom Ince expanded rapidly, absorbing firms like Ince Gordon Dadds and Plexus Legal. Behind the scenes, sole shareholder Pragnesh Modhwadia allegedly misused client money—fabricating bank statements and letters to conceal the fraud.

Containment by Categorisation

The SRA was already investigating Axiom Ince in early 2023—before the collapse. They had begun a forensic review of the firm’s accounts but failed to spot key red flags. Axiom Ince had claimed exemption from filing audited accounts, even though it didn’t qualify. That should have triggered deeper scrutiny—but it didn’t.

They were investigating. But procedural framing allowed the red flags to remain unaddressed.

Was It Treated Like a Service Matter?

Not formally. But the pattern fits. The SRA didn’t treat the accounting failures as urgent. It didn’t flag the financial irregularities as systemic risk. It allowed the firm to continue operating until October 2023—when £60 million had already vanished.

This wasn’t just delay. It was containment disguised as categorisation.

What the Oversight Regulator Said

In May 2025, the Legal Services Board (LSB) issued binding directions to the SRA under the Legal Services Act—the first time these powers were used. They found that the SRA:

• Failed to act adequately, effectively, or efficiently
• Did not take all the steps it could or should have taken
• Required formal enforcement to correct its omissions

The LSB described the accounting failure as a “double regulatory failure”—one by the accountants, and one by the SRA.

Why Wasn’t It in the Public Domain?

Most coverage stayed inside the legal echo chamber—Legal Gazette, Legal Futures, and the Serious Fraud Office (SFO)’s own GOV.UK page.

Mainstream outlets like BBC News, The Guardian, The Times, or The Telegraph didn’t run sustained public-facing coverage. If they mentioned it at all, it was brief and buried.

The legal world knew. The regulators knew. But the public didn’t.

This gap in coverage is not just informational—it is a barrier to public consent and accountability

Why This Matters to Litigants in Person

The Axiom Ince scandal wasn’t just a financial collapse—it was a containment of information. The system protected itself. But it didn’t protect the public.

Even with massive misconduct, the SRA didn’t act until the damage was done.

This capsule documents how categorisation and delay enabled systemic harm—while the regulator remained visibly present but procedurally absent.

Where to Find the Evidence

For those building their own contradiction-proof records, the following sources confirm the timeline and failures:

• Legal Futures and Law Gazette: Search “Axiom Ince SRA investigation 2022” or “Pragnesh Modhwadia client account fraud”
• SRA official statements: Look for press releases from late 2022 through October 2023
• Legal Services Board (LSB): Search “LSB binding directions Axiom Ince” (May 2025)
• Serious Fraud Office (SFO): GOV.UK hosts their confirmation of the criminal investigation

This capsule doesn’t just document oversight. It exposes containment—and why that matters to every Litigant in Person who’s ever been told to trust the system.

The Architecture of Avoidance (Still being performed)

The SRA’s structure is designed to regulate, investigate, and enforce. But for Litigants in Person, that architecture often performs oversight without delivering remedy. This capsule documents how the system is built—and how its design enables avoidance.

Governance & Leadership

• Board: Sets strategic direction; includes oversight subcommittees
• Chief Executive: Paul Philip (as of 2025); leads operational delivery
• Senior Management Team: Implements strategy and oversees departments

Regulatory Purpose

• Mandate: Protect the public, uphold legal standards, maintain trust
• Scope: Regulates over 200,000 solicitors and 11,000+ firms

Core Functions —Setting Standards

• SRA Handbook & Code of Conduct
• Solicitors’ Accounts Rules
• Mandatory Professional Indemnity Insurance

Routine Audits and Spot Checks

• Planned audits for high-risk firms
• Unannounced spot checks for anomalies

These checks often focus on paperwork and surface compliance. They rarely detect client harm unless it’s glaring. For Litigants in Person, this means a firm can pass inspection while mishandling a case—because the audit isn’t designed to catch that kind of harm.

Investigating Misconduct

• Complaints submitted online or directly
• Initial triage to determine scope
• Case assessment may involve evidence review

Enforcement & Sanctions

• Outcomes range from warnings to SDT referrals
• SDT decisions are public and binding
• SRA may publish regulatory decisions independently

Deflection by Design

When Oversight Protects the System, Not the Public

The SRA doesn’t act when things go seriously wrong. And when it finally does, it’s often too late—and too quiet.

Complaint Handling Process

Stage 1: Triage

• Determines if it’s a “service matter” (redirected to Legal Ombudsman) or “conduct matter” (retained by SRA)

Stage 2: Assessment

• If retained, checks for rule breach
• Many cases closed without investigation if deemed low risk

Stage 3: Investigation

• Formal inquiry may begin
• Supposed to gather evidence, including client communications and billing records

Stage 4: Outcome

• May issue advice, take no action, or apply sanctions
• Right to appeal or escalate may be limited

Regulatory Performance vs Protection (Measured in real time)

This capsule documents how the SRA’s performance—when measured in real time—fails to protect the public. The Axiom Ince scandal is not just a financial collapse. It is a live demonstration of regulatory inadequacy.

Visibility Without Remedy

 When Oversight Performs, But Doesn’t Protect

This capsule does not retell the Axiom Ince case. That evidence is already documented.

Instead, it examines how the SRA’s public-facing performance concealed systemic failure—and why that concealment matters.

The regulator was visible: issuing statements, conducting reviews, and appearing engaged.

But visibility did not equal remedy. The architecture allowed harm to unfold while oversight was being performed.

For Litigants in Person, this is not just a procedural flaw. It’s a breach of trust.

Because when the system performs fairness without delivering protection, it invites engagement under false pretences.

This capsule documents how visibility without remedy functions as containment—especially for those without representation.

Visibility Without Engagement (No reply, no remedy)

This capsule documents how the SRA performs oversight without engagement. It shows how acknowledgment becomes a placeholder, how silence becomes strategy, and how Litigants in Person are left exposed while firms reshape their narrative.

The Gatekeeper’s Delay — A Forensic Record of Strategic Pausing

The SRA acknowledged receipt of my submission on 12 August 2024. That acknowledgment marked the beginning of a procedural pause—not a response, not an engagement, but a placeholder. The delay that followed was not incidental. It was architectural.

This capsule documents how: The SRA’s delay is not a failure to act, but a performance of process designed to stall scrutiny. By issuing acknowledgment without substance, the SRA creates the illusion of movement while preserving institutional control.

Timeline of Delay

• From acknowledgment to silence

Strategic Function

• Delay as a tool to allow firms to shape their narrative before scrutiny begins

Pattern Recognition

• This is not the first delay—it is part of a repeated pattern of procedural delay across Litigant Records I–III

This capsule does not ask for urgency. It documents how urgency is denied by design.

When the Ruling Wasn’t Enough

 The Attempted Re-entry After Judicial Refusal

A district judge ruled on 11 August 2022that neither party was to attend the property during the Single Joint Expert’s inspection. The ruling was clear, repeated, and recorded in the transcript:

“If I heard of it, I would not allow it.” 

“You are then in a position where the expert is potentially coming under pressure from one side or the other, and that is not fair on the expert.”

(Direct Judge - 11/08/2022)

Despite the judicial ruling, the defence solicitor pushed for access through courtroom arguments — and failed. My own solicitor then attempted to grant access through a backdoor route, involving video link proposals and unofficial amendments to the Consent Order — against her client’s explicit instructions. The February 2023 correspondence reveals a coordinated effort to bypass the ruling.

• Requests for video consultation during the inspection
• Amendments to the Consent Order to include video access, despite prior agreement
• Direct emails to the expert suggesting live contact
• The expert ultimately refused both video and telephone contact, stating it was unnecessary

This wasn’t a misunderstanding. It was a strategic attempt to rewrite the boundaries set by the court

Why This Matters to Litigants in Person

For Litigants in Person, this is more than procedural drift. It’s a warning:

• That even clear judicial rulings can be tested by those with legal authority
• That emotional safety is not guaranteed by court orders alone
• That containment tactics can continue under the guise of clarification or consent

Why I Stepped Back — When Containment Became Dangerous

By February 2023, I had formally stepped back from acting as a Litigant in Person. The court was notified. This wasn’t a procedural choice—it was a protective one. My son was no longer coping. The sustained pressure from the defence solicitor had already pushed him to the edge. His mental health had deteriorated to the point of crisis.

The defence solicitor's behaviour didn’t stop with the Judge’s ruling. He continued to push—amending consent orders without consultation, emailing the expert directly, and attempting to force agreement to a video link he knew the court would not permit.

This wasn’t advocacy. It was containment by coercion. And it was overwhelming.

I didn’t just step back—I instructed the solicitor then advising me to go on record. Not because I wanted to disengage, but because I needed to protect my son. The emotional damage was already done. The procedural breach was ongoing. And the system wasn’t stopping it.

Why This Matters

For Litigants in Person, this is the part of the record that rarely gets seen:

• That judicial boundaries can be tested repeatedly
• That mental health can be shattered by procedural aggression
• That stepping back isn’t surrender—it’s survival

When the Regulator Reframed the Breach

The SRA’s Defence of the Indefensible

After the Judge’s ruling on 11 August 2022, the defence solicitor's efforts to gain access didn’t stop. He continued through amended consent orders, direct emails to the expert, and requests for video contact. These weren’t procedural suggestions. They were sustained attempts to override a judicial boundary.

And when the SRA responded, they didn’t investigate. They rationalised. They minimised. They endorsed.

Then came the SRA’s decision.

In his refusal to investigate, Mr Lawrence Price wrote:

“This was never more than a proposal… no attempt was made to attend.”

He concluded that the defence solicitor’s actions did not amount to intimidation or unfair advantage.  (Source: SRA Investigation Officer Laurence Price, report dated 25 October 2024)

This wasn’t just minimisation—it was endorsement. The regulator didn’t just fail to act. It validated the solicitor’s behaviour, despite transcript evidence, email trails, and the emotional toll it caused.

Why This Matters

For Litigants in Person—and for anyone who’s ever trusted a court order to protect them—this sends a chilling message:

• That court orders can be softened by regulators
• That emotional harm is invisible unless institutionalised
• That solicitors can breach boundaries and still be defended by oversight bodies

Structural Silence

• The architecture allows the SRA to remain visible without being answerable
• Acknowledgment replaces engagement
• Procedure replaces scrutiny

Visibility Without Engagement

 A Forensic Record of Performed Access

• The SRA is visible. It has a website, a complaints portal, published decisions, and public statements. It appears accessible. But for Litigants in Person, that visibility does not lead to engagement. It leads to containment.
• This capsule documents how the SRA performs openness while avoiding scrutiny. It’s not about being reachable—it’s about being seen to be accessible.

Service Matter as Deflection

A Forensic Record of Misclassification

• When I raised serious concerns about professional conduct, the SRA didn’t investigate. Instead, they reclassified my complaint as a “service matter” and redirected it to the Legal Ombudsman. That wasn’t a mistake. It was a strategy.
• This capsule documents how the “service matter” label is used to deflect scrutiny. It’s not about resolving harm. It’s about reframing it—so it falls outside the SRA’s regulatory scope.

Decision-Maker Index–SRA Edition 

A Forensic Record of Distributed Authority

The SRA operates through layers of decision-making. From triage to enforcement, each stage involves individuals or teams who shape outcomes—but rarely hold visible accountability. This capsule documents how decision-making is structured to disperse responsibility while preserving control.

For Litigants in Person, this means the system is not faceless—it is multi-faced. And each face is trained to redirect, defer, or contain.

Triage Officers

• First point of contact
• Decide whether a complaint is a “service matter” or “conduct matter”
• Their decisions shape the entire trajectory—but their reasoning is rarely shared

Assessment Teams

• Review complaints for regulatory breach
• Can close cases without investigation, citing “low risk” or “insufficient evidence”
• Their discretion is final—and largely invisible

Investigators

• If a case proceeds, they gather evidence
• Their scope is limited by earlier classifications
• They do not revisit triage decisions

Internal Reviewers

• Handle appeals or reconsiderations
• Not independent panels—they are part of the same structure
• Reviews often uphold prior decisions without fresh scrutiny

Senior Management & Legal Advisers

• Oversee policy and complex cases
• Influence thresholds, priorities, and outcomes
• Rarely appear in correspondence

Board & Chief Executive

• Set strategic direction
• Role is governance, not casework
• Their decisions define what counts as risk, harm, or public interest

Why This Index Matters

This capsule does not name individuals. It names roles that perform containment. It shows how decision-making is distributed to avoid accountability—and how Litigants in Person are left navigating a system where no one is answerable, but everyone is involved.

Across Litigant Records I–IV, this index reveals a structured performance of discretion. It is not a failure of oversight. It is a design of avoidance.

From Visibility to Decision-Making

The SRA’s visibility is not faceless—it is structured.

Every silence, every redirection, every non-response is shaped by someone, somewhere, within a role designed to contain.

That’s why the next capsule doesn’t just ask why decisions are made.

It asks who makes them—and how their authority is distributed to avoid accountability.

You’ve seen the stage.

Now let me show you the rigging

Lip IV_Page 2_II. The Legal Ombudsman – The Loop of Non-Remedy.

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