Bolt Services UK Limited v The Commissioners for HMRC

Decision date: 5 March 2025

Neutral citation: [2025] UKFTT 302 (TC)

Overall AI summary confidence: high

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Short overview

This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.

AI confidence in this short overview: high

Transopco (FreeNow) applied for non-party disclosure of documents from Bolt Services' FTT appeal against HMRC. The Tribunal applied common-law principles requiring a non-party to show a "good reason" related to open justice, and granted disclosure in part: transcripts (subject to Transopco paying 20% of Bolt's costs), pleadings (Bolt's Grounds of Appeal, HMRC's Statement of Case, Bolt's Reply), the parties' skeleton arguments, the statement of agreed facts, and Joshua Ryan's witness statement (but not its exhibits). The Tribunal refused disclosure of expedition materials, permission-to-appeal papers, the exhibits to the witness statement, and the full hearing bundle on grounds of confidentiality, volume and disproportionate burden, and made directions and timelines for provision, redaction and cost contribution.

Ratio decidendi

This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.

AI confidence in this ratio decidendi summary: high

A non-party seeking disclosure from FTT proceedings must first show a "good reason" explaining how disclosure advances the interests of open justice; this is a threshold requirement. Pleadings, skeleton arguments and written submissions attract a low threshold for disclosure because they are central to understanding proceedings, but countervailing factors (confidentiality, proportionality, administrative burden and the availability of other materials) can justify refusal of particular documents.

Obiter dicta

This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.

AI confidence in this obiter dicta summary: medium

The Tribunal commented that it is reasonable for a non-party to contribute to the cost of providing transcripts rather than receiving them free, and that voluminous or commercially sensitive bundles/exhibits may be withheld where redaction would be disproportionately onerous; it suggested specific-item applications might follow review of disclosed materials.