Shahada Rahman Joli v The Commissioners for HMRC
Decision date: 12 August 2026
Neutral citation: [2026] UKFTT 1204 (TC)
Overall AI summary confidence: high
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
This appeal concerns an application for permission to bring a 777‑day late appeal against a Schedule 24 paragraph 19 personal liability notice issued by HMRC. The Tribunal found the Appellant had a good reason for delay up to at least 14 February 2023 because of serious health problems and, balancing all circumstances (including an unclear HMRC letter and the procedural history), allowed the late appeal. The Tribunal also held it was lawful to proceed with the hearing in the Appellant’s absence and to enforce case‑management directions.
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: medium
The Tribunal applied a three‑stage approach to permission for an out‑of‑time appeal (establish length of delay; ascertain reasons for delay; balance all circumstances) as derived from Denton/Martland. It treated failings by the Appellant’s advisers generally as failings of the litigant for the second‑stage assessment but recognised that exceptions may arise; it also held that ambiguous communications from HMRC about an out‑of‑time review can materially affect whether a good reason for delay exists.
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 observed that the substantive merits of the underlying appeal should not normally be explored in detail when deciding whether to admit a late appeal, save for any plainly obvious strengths or weaknesses, and reiterated that case‑management powers (including proceeding in a party’s absence and use of UNLESS orders) must be exercised in accordance with the overriding objective to deal with cases fairly and justly.