Application by a creditor or member alleging unfair harm by an administrator

AuthorMark Watson-Gandy
Pages199-210
Chapter 13


Application by a Creditor or Member Alleging Unfair Harm by an Administrator

OBJECTIVE

A creditor or member may apply to the court to complain that the administrator is either acting or has acted in such a way as to unfairly harm his (and others’) interests as a member or creditor or proposes to act in such a way.1The application may also be made on the basis that the administrator is not undertaking his functions as quickly or as efficiently as reasonably practicable.2

The court is given a wide discretion on how to deal with the order. It may grant relief or make any other order it feels appropriate, including making an interim order3and may regulate the administrator’s functions, require the administrator to do (or not to do) specific acts, require a creditors’ meeting to be called or even end the administrator’s appointment.4The fact that the act was within the administrator’s powers or in compliance with a court order allowing the administrator to dispose of the company’s property subject to a charge or a hire purchase agreement does not prevent the court from reviewing.5

The power, however, does not allow the court to impede or prevent the implementation of:6

ƒ a company voluntary arrangement (CVA);
ƒ a compromise or arrangement sanctioned under Part 26 of the Companies

Act 2006;
ƒ a cross border merger;7

ƒ the administrator’s proposals approved by a creditor’s meeting;8

1Paragraph 74(1) of Schedule B1 to the Insolvency Act 1986.

2Paragraph 74(2) of Schedule B1 to the Insolvency Act 1986.

3Paragraph 74(3) of Schedule B1 to the Insolvency Act 1986.

4Paragraph 74(4) of Schedule B1 to the Insolvency Act 1986.

5Paragraphs 74(5), 71 and 72 of Schedule B1 to the Insolvency Act 1986.

6Paragraphs 74(6) of Schedule B1 to the Insolvency Act 1986.

7As defined in regulation 2 of the Companies (Cross Border Mergers) Regulations 2007 (SI 2007/

2974).

8Paragraph 53 of Schedule B1 to the Insolvency Act 1986.

200 Corporate Insolvency Practice

ƒ revisions to the administrator’s proposals approved by a creditor’s meeting.9

The court will also not review the reasonable decisions of an administrator to convert an administration into a creditor’s voluntary liquidation or reject a proof of debt, even if influenced by a mistake.10Nor will the court require the administrator to deploy resources to answering questions by the creditor.11

APPLICATION

The application is made by application notice using Form IAA. The application should be made on notice and the administrator should be named as respondent.

The application should set out the particulars of the allegations against the administrator and the relief sought.

COURT FEES

Where fresh proceedings need to be brought, a court fee of £280 is payable.12If

the application can be made as part of exisiting proceedings and the application is on notice to other parties, a court fee of £155 is payable.13Where the application is made by consent or without notice in existing proceedings, a court fee of £50 is payable.14

EVIDENCE

The applicant should file a witness statement in support. This should address:

ƒ the capacity in which the applicant makes this application; ƒ the date the company was incorporated;
ƒ the registered office of the company;
ƒ the nominal share capital of the company;
ƒ the issued share capital of the company;
ƒ the objects of the company;
ƒ the date of the administration order;
ƒ the purpose of the administration;

9Paragraph 54 of Schedule B1 to the Insolvency Act 1986.

10Unidare plc v Cohen [2005] EWHC 1410 (Ch), [2006] 2 BCLC 140.

11Four Private Investment Funds v Lomas; Re Lehman Bros International (Europe) (in administration) [2008] EWHC 2869 (Ch), [2009] 1 BCLC 161.

12Paragraph 3.5 of Schedule 1 to the Civil Proceedings Fees Order 2008.

13Paragraph 3.12 of Schedule 1 to the Civil Proceedings Fees Order 2008.

14Paragraph 3.11 of Schedule 1 to the Civil Proceedings Fees Order 2008.

ƒ the identity of the administrator;
ƒ full particulars of the wrongful or unfair conduct alleged against the administrator;
ƒ how the conduct of the administrator has unfairly harmed the applicant.

The witness statement should exhibit:

ƒ evidence of the applicant’s locus;
ƒ evidence of the administrator’s appointment;
ƒ evidence of the steps in issue;
ƒ any documents relevant to the issue;
ƒ any documents relevant to the facts upon which the issue arises.

SERVICE

The usual rule is that, subject to any other express provision, the application must be served at least 14 days before the date fixed for the hearing.15However, the court does have power, in cases of urgency, to hear an application immediately with or without notice to the other parties.16

Service may be effected personally17or by post in accordance with the rules on...

Get this document and AI-powered insights with a free trial of vLex and Vincent AI

Get Started for Free

Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex

Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex

Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex

Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex

Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex

Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant

  • Access comprehensive legal content with no limitations across vLex's unparalleled global legal database

  • Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength

  • Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities

  • Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting

vLex