Application by a secured creditor to enforce his security/bring proceedings during an administration

AuthorMark Watson-Gandy
Pages227-237
Chapter 15


Application by a Secured Creditor to Enforce his Security/Bring Proceedings during an Administration

OBJECTIVE

The conduct of an administration precludes a secured creditor from enforcing his security.1There are two exceptions to this rule. Firstly, where he obtains the consent of the administrator2and, secondly, where he obtains the consent of the court.3

Similar provisions apply to bar, during the course of the administration (without either the consent of the administrator or permission of the court), the repossession of the company’s goods,4the exercise by a landlord of his right of forfeiture or peaceable re-entry,5or the start or continuation of legal process against the company or its property.6Legal process, for this purpose, includes legal proceedings, execution, distress and diligence.7

When considering whether to grant permission, the court will balance the proprietary interests of the secured creditors against the interests of the unsecured creditors.8Thus the court will normally grant an application where refusal will cause significant loss to a creditor9or where granting the order would not impede the purpose of the administration,10but refuse it where the secured asset is necessary for the continuation of the company’s business during the administration.11

1Paragraph 43(2) of Schedule B1 to the Insolvency Act 1986.

2Paragraph 43(2)(a) of Schedule B1 to the Insolvency Act 1986.

3Paragraph 43(2)(b) of Schedule B1 to the Insolvency Act 1986.

4Paragraph 43(3) of Schedule B1 to the Insolvency Act 1986.

5Paragraph 43(4) of Schedule B1 to the Insolvency Act 1986.

6Paragraph 43(5) of Schedule B1 to the Insolvency Act 1986.

7Paragraph 43(5) of Schedule B1 to the Insolvency Act 1986

8Fashoff (UK) Ltd v Linton [2008] EWHC 537 (Ch), [2008] BCC 542.

9Re UK Housing Alliance (North West) Ltd, Mackay v Kaupthing Singer & Friedlander [2013]

EWHC 2553 (Ch).

10Metro Nominees (Wandsworth) (No 1) Ltd v Rayment [2008] BCC 40.

11Innovate Logistics v Sunberry Properties [2008] EWCA Civ 1321.

228 Corporate Insolvency Practice

APPLICATION

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

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 existing 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 serve a witness statement in support. This should address:

ƒ the capacity in which the deponent makes the application (e.g. holder of security);

ƒ the nature of the applicant’s interest;
ƒ the value of the asset;
ƒ the nature of the security if any;
ƒ the value of the debt owed to the applicant;
ƒ what steps the applicant wishes to take;
ƒ how the applicant’s entitlement arises (but for the moratorium) to take the steps he proposes to take;
ƒ the date of the administration order;
ƒ the purpose of the administration;
ƒ that the moratorium created by the administration prevents his taking the proposed steps without the consent of the administrator or the permission of the court;
ƒ whether the administrator’s consent has been sought and his response;
ƒ that the applicant seeks permission from the court;
ƒ the nature of the hardship caused to the applicant by being unable to take the proposed steps;
ƒ how taking the proposed steps will affect the likely achievement of the objectives of the administration;
ƒ how taking the proposed steps will affect the interests of the unsecured creditors;
ƒ the nature of the asset.

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.

The witness statement should exhibit:

ƒ evidence of the interest that the applicant seeks to enforce;
ƒ evidence showing the entitlement to take the proposed steps proposed by the applicant;
ƒ evidence of the level of debt;
ƒ evidence of the value of the asset (if applicable);
ƒ any documents relevant to the issue;
ƒ any documents relevant to the facts upon which the issue arises.

SERVICE

The...

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