Vehicle Control Services Ltd v Langley [2026] EWCC 1 (07 January 2025)

Mr Boaten does not have a right of audience because he has not assisted in the conduct of litigation, is not under the supervision or instruction of an authorised litigator, and the lay client is not present. The statutory exemptions do not apply, and the court's discretion was not invoked.

Citation: [2026] EWCC 1
Parties: Claimant: Vehicle Control Services Limited; Defendant: Stephen Langley
Jurisdiction: England and Wales
Judgment Date: 07 January 2025
Procedural Posture: Small Claims (county Court) / Preliminary Issue on Right of Audience
Outcome: Application refused; Mr Boaten has no right of audience.
Legal Topics: Rights of Audience, Solicitor's Agents, Exempt Persons Under Legal Services Act 2007, Small Claims Procedure

Civil Procedure Legal Profession Regulation Rights of Audience Solicitor's Agents Exempt Persons Under Legal Services Act 2007 Small Claims Procedure

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 9 Party arguments 2

Parties

Vehicle Control Services Limited

Claimant

Stephen Langley

Defendant

Procedural Posture

Small Claims (county Court) / Preliminary Issue on Right of Audience

Legal Issues

1 Whether an unqualified 'Solicitor's Agent' (Mr Boaten) has a right of audience at a small claims hearing in the absence of the lay client
2 Whether the arrangements between the Claimant, its solicitors, advocacy agency, and Mr Boaten satisfy the statutory exemption for rights of audience

Ratio Decidendi

Court Disposition

Application refused; Mr Boaten has no right of audience.

Orders

Mr Boaten is not entitled to appear as advocate for the Claimant at this hearing.