KB-2023-003510 - [2025] EWHC 1755 (KB)

TCG’s riposte

Mr Laddie’s principal submission in reply amounted to criticism of the way in which Mr Dowding had supplemented and expanded his evidence about his means and his assets in answer to questions from the Court. The main points made by Mr Laddie were (1) that, both from his researches into the case law and because he is an experienced senior financial executive, Mr Dowding plainly knew and understood the requirement for “detailed, cogent and proper evidence which gives full and frank disclosure of [his] financial position”, (2) that although it would have been very easy for Mr Dowding to provide documentary evidence of the facts and matters that he had not included in his witness statement, not least by disclosing a bank statement or bank statements, Mr Dowding had not done this, and (3) in light of these points, the Court should not accept or should be slow to accept the explanations and figures that Mr Dowding had given.

TCG also produced evidence in rebuttal, in the form of the 1^st witness statement of Daniel Stanbury, a Sales Director employed by Fitzrovia, dated 24 June 2025.

The first principal matter addressed in that witness statement concerns proceedings that Mr Dowding has intimated against Mr Stanbury and others. Mr Stanbury explains:

The second principal matter addressed in that witness statement concerns the issue of whether, as alleged by Mr Dowding in the Fraud Proceedings, Mr Stanbury’s signature on the Fitzrovia Report (in other words, the 8 November 2023 letter) is “not genuine”. Mr Stanbury states at [6] of his witness statement:

“6.1

I understand that Mr Dowding is casting doubt on whether I signed and initialled the 8 November 2023 letter and its attachments. I understand that Mr Dowding has sought expert evidence from two separate experts to ascertain whether the signature on this letter was forged. I exhibit at pages 13 - 40 of DS1 the two expert reports which Mr Dowding provided to The Character Group. Mr Dowding has separately provided copies of these same reports, albeit without the cover page shown at page 26 of Exhibit DS1 and with a different case name and court name and number, to Pinsent Masons on 2 April 2025. The first page of the 8 November 2023 letter can be seen on pages 23 and page 38 of Exhibit DS1. I exhibit at pages 1 - 12 of DS1 the full version of the 8 November 2023 letter and its attachments as sent to Pinsent Masons on 2 April 2025.

6.2

I have previously confirmed to Mr Dowding … my recollection of how and when I signed the 8 November 2023 letter and initialled its attachments. However, for the avoidance of doubt, I have set out below, once again, the process by which the 8 November 2023 letter and its attachments came to be initialled and signed:

6.2.1

On 8 November 2023 I attended Allenby’s offices as part of our usual monthly IT update. Allenby had printed a copy of the 8 November 2023 letter (which had been settled through an exchange of drafts between me and Allenby) and had printed the attachments to my 20 June 2022 email, which were the SMTP headers of four emails dated 2 August 2017 between Amrit Nahal of Allenby and Kiran Shah of the Character Group. I did not have access to a printer at Fitzrovia’s offices which is why Allenby printed it for me.

6.2.2

During the meeting, I signed the printed letter and initialled the printed attachments to confirm their authenticity and provided these copies to Allenby.

6.2.3

I did not keep a copy of the signed letter as Allenby retained this.

6.3

For the avoidance of doubt, I remember that I signed the 8 November 2023 letter and initialled its attachments. I confirm that I recognise my signature and my initials on the 8 November 2023 letter and its attachments, as exhibited at pages 1 - 12 of DS1. I have no reason to believe that the signature or initials on this letter are inauthentic.”