A short list this week, but two judgments worth reading. NCA v GKC (No 2) [2026] EWHC 929 (Admin) is Fordham J’s sequel to NCA v GKC (No 1) [2026] EWHC 573 (Admin) on UWOs and IFOs: the interim anonymisation imposed at the without-notice stage is discharged after a separate, on-notice public hearing with media intervention, and the judgment is now the leading recent treatment of the open-justice/Article 8 balance in Part 8 (UWO/IFO) proceedings. N & CJ Horton Property v Ivan Norman & Conjoined Appeals [2026] EWHC 959 (Ch) is a Chancery Appeals decision of Leech J on pleading allegations of POCA money-laundering offences (ss.327–329) in civil claims — the kind of authority that reaches well beyond the Chancery list and is the first Part 7 judgment in the corpus. No POCA-relevant legislation or SIs were made or came into force in the period.

New judgments

[2026] EWHC 929 (Admin) — National Crime Agency v GKC (No 2)

Court: High Court (KBD, Administrative Court), London Date: 24 April 2026 Judge: Mr Justice Fordham
POCA provisions: ss.362A, 362B, 362I, 362J POCA 2002 (Part 8 — UWO and IFO); CRP Practice Direction §11.1
Link: https://caselaw.nationalarchives.gov.uk/ewhc/admin/2026/929

The sequel to NCA v GKC (No 1) [2026] EWHC 573 (Admin), in which Fordham J had refused to discharge an UWO and IFO obtained by the NCA without notice from Bourne J on 18 July 2025. The remaining issue — heard in a separate, on-notice hearing with intervention by the BBC, Times Media, Associated Newspapers and Telegraph Media — was whether the interim anonymisation and reporting restrictions imposed at the discharge hearing should be maintained or discharged. The NCA and the media interveners agreed that they should be discharged; the respondent resisted. Fordham J holds that the individualised Article 8 / Article 10 balance comes down decisively in favour of discharge once the discharge application has failed on its merits. The judgment is the most useful recent restatement of the open-justice contours in Part 8 proceedings (citing Marandi, Hussain§88, Javadov, Briedis, Hao and Simms-Davies v Southwark Crown Court [2026] EWHC 337 (Admin)) and of how the ZXC v Bloomberg reasonable expectation of privacy is to be reconciled with the standard CRP Practice Direction route of private without-notice → public on-notice hearings.

[2026] EWHC 959 (Ch) — N & CJ Horton Property v Ivan Norman & Conjoined Appeals

Court: High Court (Chancery Appeals) Date: 24 April 2026 Judge: Mr Justice Leech
POCA provisions: ss.327, 328, 329 POCA 2002 (Part 7 money-laundering offences); s.340 (criminal conduct / criminal property)
Link: https://caselaw.nationalarchives.gov.uk/ewhc/ch/2026/959

Conjoined appeals (the Ivan, Dean and Crump Appeals) from Master Clark’s reserved judgment of 29 November 2024 ([2024] EWHC 2994 (Ch)). On all three applications the same issue arose: whether the appellants had a real prospect of persuading the trial court that the respondents were parties to a money-laundering scheme contrary to ss.327–329 POCA. Master Clark had found they did not — refusing permission to amend the Ivan and Dean particulars and granting summary judgment striking out part of the Crump defence. Leech J’s judgment is a workmanlike restatement of how the POCA Part 7 offences operate when pleaded as part of a civil claim: the mens rea threshold (“knew or suspected”), the overlap between ss.327, 328 and 329 (the same conduct can fall under more than one section — R v Fazal [2010] 1 WLR 694 [17]), the role of the predicate offence in proving “criminal property”, and the standard the pleader must meet at the strike-out / amendment / summary-judgment stage. It is the first Part 7 case to enter the corpus and a useful citation for any practitioner pleading or resisting civil ML allegations.

Legislation & SIs

No new POCA-relevant primary legislation or statutory instruments were made, came into force, or had a relevant amendment commenced in the coverage period. The most recent POCA-titled SIs remain SI 2025/877 (Money Laundering Threshold Amount Amendment) and SI 2025/537 (References to Financial Investigators Amendment).

Narita Bahra KC recognised in Doyles

Flavia Kenyon explores her recent success in the Court of Appeal