Letters to the Judicial Appointments Commission: Multiple identities, compromised accounts, flawed KYC.

JAC prevaricates in responding to a Freedom of Information request.

From 15 June 2023 I made complaints about the following seven Judicial Commissioners who had failed to register interests, five of whom have multiple identities registered in Companies House:

• Helen Pitcher - 5 identities in Companies House

  • In the 2022-2023 Register of Interests Helen Pitcher failed to register interests: Sustainable Boardroom Excellence Limited, Balance in Business Limited, Kids Out Trading Limited, United Biscuits (UK) Limited and Kids out UK.

  • There are companies disclosed in her biography that are not supported by evidence registered in Companies House: C&C Group PLC, IAA ExCo, and Global Clubs, as well as past appointments to Saville Group PLC and Pladis Global.

  • Possesses five identities that enable the concealment of interests and raise concerns about transparency and accountability and meets the definitions of fraud in the Fraud Act, 2006, evidence of synthetic identity fraud.

• Anuja Dhir - 2 identities in Companies House

  • Failure to register interests: Place2be and the London Symphony Orchestra Limited.

  • Investigation requested regarding the registration of recently resigned directorships of LSO Productions Limited and The City Academy Hackney.

  • Distribution of appointments across multiple identities is evidence of synthetic identity fraud.

• Jane Furniss 3 identities in Companies House

  • Failure to register: Imperial Court (Kennington Lane) Management Company Limited.

  • Request investigation into ongoing influence related to The Workforce Development Trust Limited.

  • Investigate why her appointment to Critical Eye could not be substantiated.

  • Distribution of appointments across multiple identities is evidence of synthetic identity fraud.

• Andrew Kennon 3 identities in Companies House

  • Failure to register directorships of Dryden Court (Freehold) Limited, Dryden Court (Trustees) Limited, and Industry and Parliament Trust in the Register of Interests and biography.

  • Unclear affiliation with Global Partners Governance: Request for clarification of which Global Partners Governance company he works for due to similarly named registered companies.

  • Distribution of appointments across multiple identities is evidence of synthetic identity fraud.

• Sarah Lee 1 identity in Companies House

  • Failure to declare Rare Recruitment Limited, appointed 22 August 2022.

  • Inaccuracies and inconsistencies in Slaughter and May engagements, including the registration of Slaughter and May partnerships, directorship roles, and omissions in her biography of The RCJ and Islington Citizens Advice Bureaux, Trexco Limited, Slaughter and May Services Company, Trusec Limited, Slaughter and May Trust Limited, Trucidator Nominees Limited, and Slaughter and May Limited.

  • There are no records to support her assertion that she was a partner of Slaughter and May from 15 December 2008 to 31 December 2020. There is no Slaughter and May Partnership registered in this name. Ms Lee was a director of six Slaughter and May companies, which are not included in her biography, from 1 May 1999 to 15 December 2008.

  • Investigate whether Slaughter and May meet their obligations regarding reporting their activities as a group.

  • Investigate whether she was acting as Corporate Identity, Trusec which holds registrations to 44 companies, 2 active, in one identity and a further 1468 companies, 7 active in a duplicate identity.

  • Inaccurate use of Slaughter and May's name in the address of The RCJ and Islington Citizens Advice Bureaux. Between 16 May 2007 and 15 February 2019 she was a director of The RCJ and Islington Citizens Advice Bureau and using Slaughter and May's name in the address, appointed on 16 May 2007, resigned on 15 February 2019.

  • Breach of separation of duties due to simultaneous involvement with the Financial Ombudsman Service and The Independent Press Standards Organisation (IPSO).

• Emir Khan Feisal 7 identities in Companies House

  • Inclusion of dissolved company 360 Change Consulting Limited in the Register of Interests, misrepresenting the current status of the company.

  • Distribution of appointments across multiple identities, reversing his first name for six of these, is evidence of synthetic identity fraud.

• Sue Hoyle 1 identity in Companies House

  • Inaccurate Company Name:
    Sue Hoyle incorrectly references "Fuel Productions Ltd" as "Fuel (Fuel Theatre Productions)" in the Register of Interests.

  • Omission of Directorship:
    While Hoyle's trusteeship of the "Royal Opera House Covent Garden Foundation" is registered, her directorship of the company with the same name is not disclosed. She does, however, have "Royal Opera House Covent Garden Foundation registered under her profile.

  • Unnecessary Detail:
    The addition of "(Royal Court Theatre)" to "English Stage Company" in her husband's interests is deemed unnecessary.

  • Outdated Information:
    Her husband, Graham Thomas Devlin, resigned from "Diverse City" on 10 May 2023, yet this resignation is not updated in the Register of Interests.

  • Sole Trader Ambiguity:
    Sue Hoyle's appointment as a "sole trader" cannot be located in Companies House. The complainant requests additional information.

  • Request for Confirmation of Other Identities:
    The complainant asks that Sue Hoyle confirm whether or not she has other identities registered in Companies House.

I have published a number of articles describing the correspondence with the Judicial Appointments Commission relating to this:

Judicial Appointments Commission is compromised by synthetic identity fraud.

JAC's Sarah Lee - multiple breaches

Judicial Appointments Commission. Complaint about commissioner Anuja Dhir.

JAC's Emir Feisal is implicated in Synthetic Identity Fraud.

Helen Pitcher fails to declare interests held by her multiple identities in Companies House

My response to JAC, 11 July 23

The last email from the Judicial Appointments Commission in 2023 relating to my complaints about Commissioners with multiple identities in Companies House, compromised accounts and audits, failure to declare interests and ambiguous declarations, made it quite clear that the Head of Corporate Services of the Judicial Appointments Commission was satisfied that “we do not believe that the Nolan principles have been breached.”

Brushed off, I turned my focus elsewhere, for which I must apologise. I should have checked that the Commissioners’ Register of Interests had been updated correctly. More on that later.

On 20th September 2024 I thought to let the Judicial Appointments Commission know that registering interests under multiple identities is a breach of section 1082 of the Companies Act 2006. I hadn’t discovered this at the time of lodging my original complaints. So I sent the following email:

“From: alisonwright45@btinternet.com <alisonwright45@btinternet.com>
Sent: Friday, September 20, 2024 10:55 AM
To: JAC Complaints <complaints@judicialappointments.gov.uk>
Subject: Re: RE: RE: Complaint re Helen Pitcher

Dear Ms. Barling and Mr. Thomson,

Thank you for your response regarding my concerns about the declarations of interests by Commissioners of the Judicial Appointments Commission (JAC).

I wish to bring to your attention a specific legal breach that has significant implications: Section 1082 of the Companies Act mandates the use of unique identifiers for individuals involved in company records. The presence of multiple identities for over half the Board members constitutes a breach of this section. This situation compromises the integrity of accounts and KYC processes, obstructs proper audits, and increases risks related to financial misconduct.

Furthermore, this breach directly contravenes several Nolan Principles:

1. Integrity: Multiple identities obscure transparency and accountability, potentially allowing individuals to evade scrutiny and influence decisions improperly.

2. Accountability: The lack of unique identifiers hinders effective oversight and accountability, as it becomes challenging to trace individuals' actions and responsibilities accurately.

3. Openness: Transparency is compromised when individuals can operate under multiple identities, which may conceal conflicts of interest or undisclosed relationships.

4. Honesty: The existence of multiple identities raises questions about the accuracy and truthfulness of declarations made by Commissioners.

Given these breaches, I urge the JAC to reconsider its stance on this matter. Addressing these issues is crucial for maintaining public trust and ensuring that the Commission operates in accordance with legal requirements and ethical standards.

I appreciate your attention to this matter and look forward to your response.

Sincerely,
Alison Wright”

I received this response:

“From: Jessica.Murphie@judicialappointments.gov.uk
To: alisonwright45@btinternet.com Cc: complaints@judicialappointments.gov.uk
Sent: Tuesday, November 5th 2024, 13:16
Subject: Complaint Response

Good afternoon Ms. Wright,

Please accept my apologies that the response to your complaint has been delayed.

Thank you for your correspondence regarding this matter. After a thorough review of all previous communications, including the responses provided by Mr. Thomson and Ms. Barling, we can confirm that the Judicial Appointments Commission does not believe the Nolan Principles have been breached in this instance.

As such, we do not have further information to add beyond our prior responses.

Kind regards,

Jessica Murphie
Freedom of Information and Complaints Manager | Judicial Appointments Commission”.

I immediately followed this up with this Freedom of Information Request (my emphasis in bold):

“From: Alison Wright <alisonwright45@btinternet.com>
Sent: Tuesday, November 5, 2024 7:43 PM
To: Murphie, Jessica <Jessica.Murphie@judicialappointments.gov.uk>
Cc: JAC Complaints <complaints@judicialappointments.gov.uk>
Subject: Re: Complaint Response

Dear Ms. Murphie,
Thank you for your response dated November 5, 2024. I am deeply disappointed that the Judicial Appointments Commission (JAC) continues to dismiss the serious issues I have raised without thoroughly addressing them.
I must emphasise that my original complaint regarding Helen Pitcher, and subsequent concerns about other Commissioners, relate to potential breaches of Section 1082 of the Companies Act 2006. These breaches, involving multiple unique identifiers in Companies House records and failures to disclose all interests, directly undermine the Nolan Principles, particularly those of Integrity, Openness, and Honesty.
Your response fails to engage with the specific legal and ethical concerns I have raised. The existence of multiple identities in official records for public office holders is a matter of significant public interest and potential misconduct. It is not sufficient to simply state that the JAC believes no breach of the Nolan Principles has occurred without providing a detailed explanation of how this conclusion was reached.
Given the unsatisfactory nature of the responses I have received thus far, I am formally requesting, under the Freedom of Information Act 2000, all correspondence within the Judicial Appointments Commission and with any external advisors regarding myself and my enquiries since the initiation of my complaint. This should include, but not be limited to:
1. Internal emails, memos, and meeting minutes discussing my complaints
2. Any legal advice sought or received regarding the issues I have raised
3. Correspondence with the Commissioners named in my complaints
4. Any documents related to the review process of my complaints
I believe this information is crucial to understanding how the JAC has handled this matter and to ensure transparency in the process.
Furthermore, I request a detailed explanation of:
1. How the JAC has verified the accuracy and completeness of Commissioners' disclosures
2. What steps, if any, have been taken to investigate the discrepancies I have identified in Companies House records
3. The JAC's interpretation of how multiple unique identifiers align with the Nolan Principles, particularly Integrity and Openness
I remind you of the JAC's obligation to uphold the highest standards of public office and to thoroughly investigate any potential breaches of these standards. Your current stance appears to fall short of these obligations.
I look forward to receiving the requested information within the statutory 20 working days, as well as a more comprehensive response to the serious issues I have raised.
Yours sincerely,

Alison Wright”.

This was acknowledged, three weeks later:

“From: FOIA
Sent: Tuesday, November 26, 2024 2:59 PM
To: 'Alison Wright' <alisonwright45@btinternet.com>
Cc: JAC Complaints <complaints@judicialappointments.gov.uk>; FOIA <FOIA@judicialappointments.gov.uk>
Subject: FOIA Acknowledgement

Good afternoon,

Thank you for your Freedom of Information request of 5 November 2024.

Please be advised that your request is being handled under the Freedom of Information Act 2000.

The Judicial Appointments Commission is required under section 10(1) of the FOIA to provide you with a response within 20 working days. Therefore, we aim to provide you a response to your request by 3 December 2024.

If you have any queries regarding this Freedom of Information request, please do not hesitate to contact me via e-mail: FOIA@judicialappointments.gov.uk.

Kind regards,

Jessica Murphie
Freedom of Information and Complaints Manager | Judicial Appointments Commission”

On 3rd December 2024 the Judicial Appointments Commission extended the deadline for response from 3 December 2024 to 3 January 2025.

“From: FOIA <FOIA@judicialappointments.gov.uk>
Sent: Tuesday, December 3, 2024 4:34 PM
To: Alison Wright <alisonwright45@btinternet.com>
Cc: JAC Complaints <complaints@judicialappointments.gov.uk>; FOIA <FOIA@judicialappointments.gov.uk>
Subject: SAR Deadline Extension

Good afternoon,

The Judicial Appointments Commission (JAC) are treating the Freedom of Information (FOI) request that you submitted on 5th November 2024 as a Subject Access Request (SAR).

This is because your request relates to your personal information that the JAC hold in relation to your previous complaints. The JAC had intended to respond to your Subject Access Request in line with the deadline previously stated for the FOI request, by 3 December 2024.

However, in line with the Information Commissioner’s Office (ICO) guidance, the JAC consider your request to be a complex one and therefore we require additional time to ensure a thorough and accurate response.

The reasons for it being deemed complex is because the information requested contains a mixture of information that is your personal data, personal data about other people and information that is not personal data. The JAC has a responsibility to protect other people’s rights over their information and has to consider the content of each document to assess the information they contain.

Also, in some documents, your personal information is included in confidential communications between the JAC and its legal advisors. This information is considered privileged and the JAC is required to assess each document and obtain specialist legal advice in that respect.

Therefore, the JAC are extending the response deadline by an additional calendar month to 3 January 2025.

Thank you for your understanding.

Kind regards,

Jessica Murphie
Freedom of Information and Complaints Manager | Judicial Appointments Commission”

On 20th December 2023 a query, about what “all” means, was raised by the Judicial Appointments Commission:

“From: FOIA@judicialappointments.gov.uk
To: alisonwright45@btinternet.com Cc: FOIA@judicialappointments.gov.uk
Sent: Friday, December 20th 2024, 14:58
Subject: RE: SAR Deadline Extension

Dear Ms Wright,

On 5 November 2024, you asked for the following information from the Judicial Appointments Commission (JAC) relating to yourself:

All correspondence within the Judicial Appointments Commission and with any external advisors regarding myself and my enquiries since the initiation of my complaint. This should include, but not be limited to: (…)

Further to our email of 3 December 2024, we write to request clarification of your request. We would be grateful if you could confirm the date of the complaint to which you make reference to in your request, as you have submitted a number of complaints to the Judicial Appointments Commission. This will enable us to accurately ascertain which document(s) are in scope.

Yours sincerely,

Kimberley Barling
Head of Corporate Services | Judicial Appointments Commission”

I responded:

To: FOIA;

23/12/2024 12:17

Dear Ms Barling,

Dear Judicial Appointments Commission,
Thank you for your request for clarification dated December 3, 2024. I appreciate the opportunity to provide more specific information regarding the scope of my Freedom of Information Act (FOIA) request.
To clarify, my request encompasses all correspondence and documents related to the following complaints and communications:

1. Four complaints submitted on June 15, 2023, regarding Helen Pitcher, Anuja Dhir, Emir Feisal, and Jane Furniss.
2. Complaints submitted on June 22, 2023, regarding Commissioners Sue Hoyle, Sarah Lee, and Andrew Kennon.
3. Follow-up email dated July 3, 2023.
4. Letter dated July 11, 2023.
5. Emails dated July 14, July 16, July 25, and July 27, 2023.
6. Email dated August 9, 2023.
7. Letter dated August 29, 2023.
8. Emails dated August 31, 2023, and September 20, 2024.

As stated in my initial request, I am seeking all correspondence within the Judicial Appointments Commission and with any external advisors regarding myself and my enquiries since the initiation of my complaints. This includes, but is not limited to:
Internal emails, memos, and meeting minutes discussing my complaints;
Any legal advice sought or received regarding the issues I have raised;
Correspondence with the Commissioners named in my complaints;
Any documents related to the review process of my complaints;
Additionally, I reiterate my request for a detailed explanation of:
How the JAC has verified the accuracy and completeness of Commissioners' disclosures;
What steps, if any, have been taken to investigate the discrepancies I have identified in Companies House records;
The JAC's interpretation of how multiple unique identifiers align with the Nolan Principles, particularly Integrity and Openness.
I trust this clarification provides the necessary information to process my FOIA request comprehensively. Given the extended time that has elapsed since my initial request, I look forward to receiving a timely response in accordance with the statutory requirements of the Freedom of Information Act 2000.
Yours sincerely,

Alison Wright”

Hearing nothing by the deadline of 3 January 2025 I followed this up on 6 January 2025:

_{Fwd: Re: RE: SAR Deadline Extension}

Alison Wright <alisonwright45@btinternet.com>

To: FOIA@judicialappointments.gov.uk;

06/01/2025 10:28

Dear Ms Barling,

Further to my Freedom of Information request of 5 November 2024.The JAC are extended the response deadline by an additional calendar month to 3 January 2025.

It is now 6 January 2025 and I have not received a response. This is a breach of the conditions of the FOIA.

Please let me know when I might anticipate receiving the information I have requested?

Yours sincerely

Alison Wright

I received an explanation that since I had provided clarifications on 23 December 2025 they were extending the deadline to 23 January,

From: FOIA <FOIA@judicialappointments.gov.uk>

To: Alison Wright;

06/01/2025 15:21

Good afternoon,

Thank you for your clarification e-mail of 23 December 2024 and for the follow-up e-mail of 6 January 2025.

Please accept my apologies that the response to your request has been delayed.

Per the guidance issued by the Information Commissioner’s Office, the Public Authority may treat the clarified request as a new request for information. This means that, once the Public Authority understand what is being asked for, a response should be supplied to the clarified request within 20 working days.

Your response to the JAC’s request for clarification was received on 23 December 2024. Therefore, you can expect a response to your request by 23 January 2025.

Kind regards,

Jessica Murphie
Freedom of Information and Complaints Manager | Judicial Appointments Commission |

www.judicialappointments.gov.uk | LinkedIn | Twitter |

On 23 January I received a response.

From: FOIA@judicialappointments.gov.uk
To: alisonwright45@btinternet.com Cc: FOIA@judicialappointments.gov.uk; complaints@judicialappointments.gov.uk
Sent: Thursday, January 23rd 2025, 16:15
Subject: SAR Response

Good afternoon,

Herewith a response to your Subject Access Request and disclosures outlined in response.

Kind regards,

Jessica Murphie
Freedom of Information and Complaints Manager | Judicial Appointments Commission

Tomorrow I’ll work out how to embed pdf files and show you what they sent me.