Ziga & Ors v Yarnold & Ors (LAND REGISTRATION - COSTS - litigants in person) [2026] UKUT 181 (LC) (07 May 2026)

Executive summary

The Upper Tribunal allowed the appeal against the First-tier Tribunal’s costs assessment in a land-registration dispute, focusing on how a litigant in person’s recoverable costs should be calculated. It held that the costs judge had not properly considered the evidence of Dr Razoq’s alleged financial loss and had instead focused on what evidence was missing, including when assessing the hourly rate and the application of the two-thirds cap under CPR r.46.5(2).

Key points

• Parties: appellants were Senada Ziga, Sensar Limited, Adil Razoq and Azdar Limited; respondents were three sets of landowners concerning 1, 5 and 9 Springbank Gardens, Wigan.
• Context: the costs dispute arose after the appellants succeeded in earlier FTT and UT proceedings concerning restrictions on registered titles.
• Holding: appeal allowed on the costs assessment issue.
• Reasoning: the Tribunal said the costs judge identified missing evidence but did not adequately consider the evidence that was actually filed to prove financial loss.
• Rule applied: CPR r.46.5(4) governs litigants in person; if financial loss is proved, recoverable time is the proven loss, otherwise the default £19/hour applies.
• No sanctions/export-control angle appears in the decision; it is a land-registration and costs ruling.

Why it matters

This decision is not about sanctions or export controls, but it matters for sovereign-risk and litigation strategy because it clarifies how courts assess self-represented parties’ claimed economic loss in complex property disputes. That can affect recoverability analysis where politically exposed, high-net-worth, or asset-structuring disputes are litigated through UK property and registration systems.

Implications

For compliance and disputes teams, the case underscores that detailed evidence of actual income loss matters more than generalized assertions that a professional was busy or in demand. In litigation strategy, parties resisting or advancing litigant-in-person costs should address both the documentary record and the causal link between time spent on the case and specific financial loss, rather than assuming the default £19/hour will control.