Delve Ram v The Commissioners for HMRC
Decision date: 12 February 2026
Neutral citation: [2026] UKFTT 249 (TC)
Overall AI summary confidence: medium
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: medium
This case is an application by Mr Delve Ram for permission to bring a late appeal against a company officer liability decision notice issued by HMRC. The Tribunal applied the three‑stage Martland test to an approximately 867‑day delay, accepted the appellant had health problems and that an initial notice was sent to the wrong recipient, but found no good reason for the prolonged inaction after HMRC’s clear directions in September 2022. Permission to appeal late was refused.
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
Where an appellant lodges an appeal within time but to the wrong recipient, the appellant must correct that error promptly after being clearly informed of the correct procedure; prolonged inaction after such clear notification, absent persuasive documentary evidence explaining the delay, can justify refusal of permission to bring a late appeal under the Martland three‑stage approach. The Tribunal treated substantial unexplained delay and lack of supporting evidence as outweighing sympathetic consideration of health issues when balancing prejudice and finality.
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, on a preliminary view, the substantive appeal did not appear strong, but it did not conduct a full merits inquiry. It also noted that adopting a “less strict” approach emphasising procedural compliance and efficiency would not have altered the result in this case.
Warning
The chunk contains duplicated and partially fragmented text; some cited authorities and paragraph references are incomplete or garbled. The provided notes are duplicated and partially fragmented and omit some cited authorities and paragraph references, so the summary may not capture all details of the full judgment.