Vehicle Control Services Limited v Stephen Langley

Vehicle Control Services Limited v Stephen Langley

Mr Boaten does not qualify as an Exempt Person because he has not assisted in the conduct of litigation nor acted under the supervision and instruction of an authorised litigator; advocacy alone is insufficient. He cannot attend as a Lay Representative without the lay client present. No right of audience exists for him under the relevant rules and statutes.

Parties
Claimant: Vehicle Control Services Limited; Defendant: Stephen Langley
Jurisdiction
England and Wales
Judgment Date
01 July 2026
Procedural Posture
Civil / Preliminary Issue Judgment
Outcome
Application for right of audience refused
Legal Topics
Rights of Audience, Solicitor's Agent, Exempt Person, Small Claims, Lay Representative
Civil Procedure Rights of Audience Solicitor's Agent Exempt Person Small Claims Lay Representative

Case Brief

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Parties

Vehicle Control Services Limited

Claimant

Stephen Langley

Defendant

Procedural Posture

Civil / Preliminary Issue Judgment

Legal Issues

  1. 1 Whether an unqualified 'Solicitor's Agent' has a right of audience at a small claims hearing
  2. 2 Whether the agent qualifies as an Exempt Person under the Legal Services Act 2007
  3. 3 Whether attendance as a Lay Representative is permissible without the lay client present

Ratio Decidendi

Mr Boaten does not qualify as an Exempt Person because he has not assisted in the conduct of litigation nor acted under the supervision and instruction of an authorised litigator; advocacy alone is insufficient. He cannot attend as a Lay Representative without the lay client present. No right of audience exists for him under the relevant rules and statutes.

Court Disposition

Application for right of audience refused

Orders

  • Mr Boaten is not entitled to be heard as of right at this hearing.
  • No right of audience granted to Mr Boaten.