CL-2018-000297, CL-2018-000404, CL-2018-000590, - [2025] EWHC 2364 (Comm)

In a footnote in its written closing submissions, SKAT also referred to paragraph 8C of Schedule 5B. That alleged that “As set out in paragraphs 3-6 above, [Mr Shah] played a significant role in the making or procuring the making of [the representations alleged by SKAT]”. I have already noted paragraphs 3, 4 and 4A, as thus cross-referenced. Paragraph 5 said that “As set out in Section G of the Particulars of Claim”, the representations allegedly made to SKAT “were made as part of fraudulent schemes by defendants acting with a common design to defraud SKAT. It is to be inferred from the facts and matters set out in the Particulars of Claim and this Schedule [i.e. every fact pleaded across c.300 pages!] that [Mr Shah] was the primary individual responsible for the making of the” representations alleged (as regards the Solo Model), alternatively the substantial majority of them. Paragraph 6 then alleged that Mr Shah carried out “acts of assistance in furtherance of the said common design …, as particularised more fully in paragraph 8 below”, and the particulars under paragraph 6 itself then made it clear that the cross-reference to paragraph 8 was intended to encompass paragraphs 8A to 8Q, with all their sub-paragraphs, covering c.18 pages. Paragraph 8, under a heading “A3. Conspiracy”, pleaded that Mr Shah was “the primary individual responsible for devising and orchestrating the Solo WHT Scheme. In concert with [specified others], [Mr Shah] participated, and provided substantial assistance, in the execution of the Solo WHT Scheme and received substantial payments and assets … directly or indirectly representing the proceeds of the Scheme”, and said that the paragraphs that followed (which included paragraphs 8A to 8Q) set out the “concerted action taken by him pursuant to the Solo WHT Scheme”.