Titan Wealth Holdings Limited & Ors v Marian Atinuke Okunola

Titan Wealth Holdings Limited & Ors v Marian Atinuke Okunola

The court had jurisdiction under its inherent common law power to grant an injunction to protect the integrity of its proceedings, even absent a cause of action or contempt, but the injunction sought was too broad, alternative remedies were available, and there was no ongoing or threatened misconduct; thus, as a matter of discretion, no injunction should be granted.

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
Jurisdiction
England and Wales
Judgment Date
20 February 2026
Procedural Posture
Civil Appeal / Appeal From High Court Decision on Application for Injunction
Outcome
Appeal dismissed
Legal Topics
Inherent Jurisdiction, Freedom of Expression, Immunity From Suit, Harassment, Court Process Integrity
Civil Procedure Injunctions Contempt of Court Human Rights Inherent Jurisdiction Freedom of Expression Immunity From Suit Harassment +1 more

Case Brief

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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

Procedural Posture

Civil Appeal / Appeal From High Court Decision on Application for Injunction

Legal Issues

  1. 1 Whether the court had jurisdiction to grant an injunction restraining abuse of the claimants’ legal team by the defendant
  2. 2 Whether the absence of a cause of action precluded the grant of such an injunction
  3. 3 The relevance of contempt of court, Article 10 ECHR, and litigation immunity to the grant of the injunction

Ratio Decidendi

The court had jurisdiction under its inherent common law power to grant an injunction to protect the integrity of its proceedings, even absent a cause of action or contempt, but the injunction sought was too broad, alternative remedies were available, and there was no ongoing or threatened misconduct; thus, as a matter of discretion, no injunction should be granted.

Court Disposition

Appeal dismissed

Orders

  • No injunction granted
  • Amended further injunction application dismissed