1. I attended the hearing before the Divisional Court on the 3 and 4 days of October 2000 when an application was heard for a Civil Proceedings Order to be made in respect of myself under section 42(1) of the Supreme Court Act 1981.

2. During the course of the hearing, I objected to the court having before it “Bench Memo/Summaries” from Crown Office and subsequently Administrative Court Lawyers or so called “Judicial Assistants”, and I requested that I be supplied with copies.

3. This request was refused by the court and I consider that as a result, I was further denied the right to an impartial and independent tribunal in breach of the rules of natural justice and article 6(1) of the Convention for the Protection of Human Rights and Fundamental Freedoms as enacted in Schedule 1 of the Human Rights Act 1998.

4. This was also of importance because the Lord Chancellor or his predecessor had appointed Lord Justice Buxton as a Lord Justice of Appeal, and also was responsible for the appointment of the Judicial Assistants.

5. After Mr Adam Tolley of counsel for HM Attorney-General had addressed the court in the morning after having referred in detail to the evidence in support of the application, I then proceeded to address the court.

6. I then proceeded to take the court through the individual action chronologies relied upon by counsel for HM Attorney-General in order to fully argue in response to the points and issues raised by him relating to the various civil actions that he had relied on that had been brought by myself.

7. I proceeded to get through some of the actions up until action 15 or thereabouts by the end of the afternoon on the 3 day of October 2000.

8. At the conclusion of the days proceedings, Lord Justice Buxton informed me that at the court would sit at 10.00 am the next morning and that I would have up until 11.45 am to address the court at which time my address would be terminated.

9. I had been given no prior indication at all by the court that there was to be any limitation of time to be imposed for my submissions.

10. The following morning on the 4 day of October 2000, I filed a Skeleton Argument with the court which dealt with the main points of law in relation to applications for Civil Proceedings Orders.

11. The court then retired for about half an hour in order to read my Skeleton Argument, and on their return I continued to proceed in addressing the court in relation to the various actions concerned but only managed to get up to action 20 as I recall by 11.50 am.

12. I was then informed by Lord Justice Buxton that I may not address the court any further and his Lordship then announced that the judgment would be delivered on 6 October 2000 at 2.00.

13. The judgment was delivered by Lord Justice Buxton and neither during the course of my submissions nor the conclusion of the judgment was I invited to address the court in relation to the length of any proposed order under section 42(2) of the Supreme Court Act 1981.

14. I had not had time to address the court in relation to this issue during the course of the proceedings at all as all of the time was taken up with going through and dealing with the issues in the various actions relied on by counsel for HM Attorney-General.

15. Even then I was not given an opportunity of addressing the court at all in respect of the remaining 26 or so actions that had been relied upon by counsel appearing for HM Attorney-General although the court had permitted him to address the court in great detail regarding all of the actions.

16. I believe therefore that I was denied natural justice by being denied the fundamental right to be heard fully in my defence and that this was simultaneously in breach of the statutory provisions of section 42(1) of the Supreme Court Act 1981 and schedule 1 article 6(1) of the Human Rights Act 1998.