Secretary of State for the Home Department v Sedico Logistics SP ZOO [2026] EWHC 222 (KB) (06 February 2026)

Secretary of State for the Home Department v Sedico Logistics SP ZOO [2026] EWHC 222 (KB) (06 February 2026)

The statutory scheme of Part II of the Immigration and Asylum Act 1999, together with the Carriers Liability Regulations 2002, expressly contemplates proceedings against persons outside the jurisdiction, satisfying the Harrods test. Therefore, under CPR 6.33(3), permission to serve the claim form out of the jurisdiction was not required for the Secretary of State's claim for leave to sell the detained transporter.

Citation
[2026] EWHC 222 (KB)
Parties
Respondent/claimant: Secretary of State for the Home Department; Appellant/defendant: Sedico Logistics Sp. z o. o.
Jurisdiction
England and Wales
Judgment Date
06 February 2026
Procedural Posture
Appeal / Judgment on Appeal Against Refusal to Strike Out Claim for Leave to Sell Detained Transporter
Outcome
Appeal dismissed
Legal Topics
Service Out of Jurisdiction, Carriers Liability, Detention and Sale of Vehicles, Interpretation of CPR 6.33(3), Application of Harrods Test

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Parties

Secretary of State for the Home Department

Respondent/claimant

Sedico Logistics Sp. z o. o.

Appellant/defendant

Procedural Posture

Appeal / Judgment on Appeal Against Refusal to Strike Out Claim for Leave to Sell Detained Transporter

  1. 1 Whether permission to serve claim form out of jurisdiction was required under CPR 6.33(3) for a claim by the Secretary of State for the Home Department to sell a detained transporter under the Immigration and Asylum Act 1999

Ratio Decidendi

The statutory scheme of Part II of the Immigration and Asylum Act 1999, together with the Carriers Liability Regulations 2002, expressly contemplates proceedings against persons outside the jurisdiction, satisfying the Harrods test. Therefore, under CPR 6.33(3), permission to serve the claim form out of the jurisdiction was not required for the Secretary of State's claim for leave to sell the detained transporter.

Court Disposition

Appeal dismissed

Orders

  • Permission to serve claim form out of jurisdiction not required under CPR 6.33(3)
  • Judge's decision affirmed