(1) No reasons were given for imposing an indefinite Civil Proceedings Order against me, apart from the court indicating that the order would be indefinite.

(2) The making of an indefinite order was disproportionate along with the making of the Order in any event.

(3) The constitution of the Divisional Court was not an fair and impartial tribunal as former Law Officers had been consulted about their appointment and the application was being brought by the Solicitor-General on behalf of the Attorney-General.

(4) The hearing before the Divisional Court was not before an fair and impartial tribunal as the court had secret bench memoranda prepared by Crown Office lawyers.

(5) The provisions of section 42(1) of the Supreme Court Act 1981 for the making of the Order were too vague and were not reasonably foreseeable along with any consequences regarding obtaining permission to institute or continue with proceedings under section 42(3) of the Supreme Court Act 1981 once the order had been made.

(6) The making of such an Order is discriminatory regarding similar Orders in Northern Ireland and Scotland under article 14 as there are some advantages regarding the making of Orders in those jurisdictions as compared with an Order under section 42 of the Supreme Court Act 1981 in England and Wales.

(7) I therefore do not consider that the making of the Civil Proceedings Order against me was established or prescribed by law under article 6(1) and 10(1) of the Convention.

(8) My application for permission to appeal to the Court of Appeal was also an unfair determination of my civil rights under article 6(1) and 10(1) as Lord Chief Justice Woolf had indicated that he had acted as Treasury Counsel on a Vexatious Litigation application whilst at the bar on behalf of HM Attorney-General. Also the judges were appointed in the same manner as before the Divisional Court.