Titan Wealth Holdings Ltd & Ors v Okunola [2026] EWCA Civ 138 (20 February 2026)

Titan Wealth Holdings Ltd & Ors v Okunola [2026] EWCA Civ 138 (20 February 2026)

The judge was wrong to conclude there was no jurisdictional basis for the injunction; the court has inherent power to grant such relief to protect its process. However, as a matter of discretion, the injunction sought was too broad, alternative remedies existed, and the proceedings were nearly concluded. Article 10, litigation privilege, and procedural factors must be considered. No injunction should be granted in this case.

Citation
[2026] EWCA Civ 138
Parties
Claimant/appellant: Titan Wealth Holdings Limited; Claimant/appellant: Titan Settlement & Custody Limited; Claimant/appellant: Gretchen Roberts; Claimant/appellant: Tiffany Roberts; Defendant/respondent: Marian Atinuke Okunola; Advocate to the Court: Matthew Donmall
Jurisdiction
England and Wales
Judgment Date
20 February 2026
Procedural Posture
Civil Appeal / Appeal From High Court Judgment on Injunction Application
Outcome
Appeal dismissed; injunction not granted
Legal Topics
Inherent Jurisdiction, Freedom of Expression, Litigation Privilege, Harassment, Court Powers, Article 10 ECHR, Section 12 Human Rights Act, Protection From Harassment Act
Civil Procedure Injunctions Contempt of Court Human Rights Inherent Jurisdiction Freedom of Expression Litigation Privilege Harassment +4 more

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 5 Authorities cited 33 Party arguments 2 Amounts and remedies 1
Sign in to unlock

Parties

Titan Wealth Holdings Limited

Claimant/appellant

Titan Settlement & Custody Limited

Claimant/appellant

Gretchen Roberts

Claimant/appellant

Tiffany Roberts

Claimant/appellant

Marian Atinuke Okunola

Defendant/respondent

Matthew Donmall

Advocate to the Court

Procedural Posture

Civil Appeal / Appeal From High Court Judgment on Injunction Application

Legal Issues

  1. 1 Whether the court has jurisdiction to grant an injunction restraining abuse of claimants' legal team by a litigant
  2. 2 Whether the cause of action rule applies post-Convoy Collateral
  3. 3 Interaction of contempt, Article 10 ECHR, litigation privilege, and procedure in injunction applications

Ratio Decidendi

The judge was wrong to conclude there was no jurisdictional basis for the injunction; the court has inherent power to grant such relief to protect its process. However, as a matter of discretion, the injunction sought was too broad, alternative remedies existed, and the proceedings were nearly concluded. Article 10, litigation privilege, and procedural factors must be considered. No injunction should be granted in this case.

Court Disposition

Appeal dismissed; injunction not granted

Orders

  • No injunction granted
  • No further relief ordered