In England and Wales, the ability to set aside judgments obtained by fraud reflects the principle articulated in the 70-year-old decision of the Court of Appeal in Lazarus Estates Ltd v Beasley [1956] that “fraud unravels everything”.

Whilst the burden on those bringing claims to set aside judgments on the basis of fraud is high and successful claims remain rare, 2025 saw a number of claims commenced and decided on the basis of this legal doctrine. This includes proceedings commenced by Lee Castleton (a former sub-postmaster and one of the most prominent individuals affected by the British Post Office scandal) against Post Office Ltd (the Post Office) and Fujitsu Services Ltd on a number of grounds, including that a prior judgment (from 2007) was obtained against him by fraud.

The recent activity in this area serves as a reminder of the delicate balance the court must strike between the finality of judgments and the need to rectify injustice. This GT Alert provides a recap of the relevant case law and looks ahead to the next step in Mr Castleton’s claim following a decision from the court on case management further to a hearing on 23 January 2026. 

Click here to read the full GT Alert.

*Special thanks to London Litigation Paralegal Francesca Neagus˘ for her valuable contributions to this GT Alert.

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Photo of Hannah Blom-Cooper Hannah Blom-Cooper

Hannah is a highly experienced commercial litigator representing individuals and corporations in relation to high-value and complex disputes which frequently involve multiple jurisdictions.

Hannah focuses in the area of disputes arising from business failure and formal insolvency process whether domestic or foreign. Hannah…

Hannah is a highly experienced commercial litigator representing individuals and corporations in relation to high-value and complex disputes which frequently involve multiple jurisdictions.

Hannah focuses in the area of disputes arising from business failure and formal insolvency process whether domestic or foreign. Hannah also provides clear and practical advice on asset recovery and asset protection both for creditors and debtors.

Hannah frequently acts for directors in the context of delinquent businesses where serious allegations of fraud and misconduct are made by the company, shareholders, creditors or an office holder –these will include claims for wrongful or fraudulent trading or disqualification proceedings. Hannah also acts for insolvency practitioners, both pre- and post-appointment, bankrupts, and companies subject to debt recovery.

Hannah is a highly experienced commercial litigator representing individuals and corporations in relation to high-value and complex disputes which frequently involve multiple jurisdictions.

Hannah focuses in the area of disputes arising from business failure and formal insolvency process whether domestic or foreign. Hannah also provides clear and practical advice on asset recovery and asset protection both for creditors and debtors.

Hannah frequently acts for directors in the context of delinquent businesses where serious allegations of fraud and misconduct are made by the company, shareholders, creditors or an office holder –these will include claims for wrongful or fraudulent trading or disqualification proceedings. Hannah also acts for insolvency practitioners, both pre- and post-appointment, bankrupts, and companies subject to debt recovery.

Photo of Maisie Stewart Maisie Stewart

Maisie is a dispute resolution lawyer and has worked on complex contentious cases of significant value across a number of sectors, including financial services, insurance and aviation.

Maisie has acted on a number of high profile domestic and international disputes in the Commercial…

Maisie is a dispute resolution lawyer and has worked on complex contentious cases of significant value across a number of sectors, including financial services, insurance and aviation.

Maisie has acted on a number of high profile domestic and international disputes in the Commercial Court and Financial List. She has also worked on regulatory investigations, defending clients in investigations concerning financial crime controls and market manipulation, and has experience of contentious restructuring and insolvency matters.

Photo of Harriet Lehain Harriet Lehain

Harriet Lehain is a member of the Litigation Practice in Greenberg Traurig’s London office. Her practice focuses on complex multi-jurisdictional commercial disputes across a range of sectors, civil fraud and regulatory investigations.