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What Judges say…




“I am grateful to your solicitors [Douglass Simon] for their carefully constructed bundle of documents, their focused and limited grounds, and their cogent argument. These features are, sadly, rare in the cases I see.”


Upper Tribunal Judge Edward Jacobs on 17th February 2016






“The notice of appeal shows that the appellant submitted detailed grounds of appeal highlighting how the decision breached her article 8 private life ties... A wealth of documentary evidence was submitted with the grounds of appeal. It is clear from the refusal letter that the Secretary of State has not given any consideration to the statement of additional grounds and documentary evidence submitted by the appellant relating to the article 8 arguments. “




“(The above), renders the Secretary of State’s decision unlawful and not in accordance with the law...”


First Tier Tribunal Judge Phull on 24/09/2015






“The Appellant’s case is fully particularised in the Grounds of Appeal submitted by the Appellant’s current Solicitors, Douglass Simon.”




“I note from the Appellant’s solicitors covering letter dated January 2013 (pages 38 – 55 of the Appellant’s bundle) was not only lengthy and detailed but also referred to (in general terms) all of the documentary evidence....”



First-tier Tribunal Judge A. Khawar granting an Appeal based on the income threshold and subsisting relation under Appendix FM of the Immigration Rules on 5th March 2015  






“…it is arguable that the Judge’s reasoning is flawed for the reasons set out in the grounds [prepared by Douglass Simon Solicitors]



Upper Tribunal Judge Allen granting permission to appeal on a complicated asylum matter from the First-tier Tribunal on 17th February 2015





“…the decision is subjected to detailed analysis…”



Designated Judge of the First-tier Tribunal Digney on an application for permission to appeal to the Upper Tribunal on a complicated asylum matter

4th February 2015





“As this arguable error of law has been identified [by the appellant’s representative] all the issues raised in the grounds are arguable.”



First-tier Tribunal Judge Osborne on 27th January 2015 in a decision granting permission to appeal to the Upper Tribunal as to whether ‘time’ can be a legitimate aim to a proportionality assessment under Article 8(2) of the ECHR – that is to say, whether an appellant ought to be allowed to remain outside the Rules whilst the appellant’s employer applies for a Tier 2 Sponsor License application which is taking and has taken a long time to consider. It was argued that ‘time’ (or rather promptness) should not be a legitimate aim in itself under Article 8(2) unless the prolongation of time can be shown to have some detriment on the ‘economic well-being’ of the state - itself, a legitimate aim under Article 8(2)






“As [the] grounds make clear…”



Upper Tribunal Judge Eshun in agreeing with our Grounds for Permission to Appeal and granting permission to appeal to the Upper Tribunal by finding that the First-tier Tribunal made an error in its approach and interpretation of the EEA (Immigration) Regulations 2006  (14th October 2014)





In allowing an appeal on a legal point of construction in respect of the Domestic Worker Rules and Statement of Changes HC628;



“In light of the detailed submissions in the skeleton argument upon which I indicated that my preliminary view was favourable…”


Judge of the First-tier Tribunal Roopnarine-Davies in a decision promulgated on 17th September 2014






In allowing an appeal, First-tier Tribunal Judge S J Widdup (on an EEA matter);


“The notice of appeal was accompanied by detailed submissions by the Appellant’s solicitors which I have read...


I agree with [their] analysis…”


First-tier Tribunal Judge S J Widdup allowing an appeal on 1st August 2014 in respect of an EEA appeal under the Imm. (EEA) Regulations 2006 and the Secretary of State’s duties on the approach to evidence of exercising Treaty Rights




In granting permission to apply for Judicial Review in complicated human rights case involving adult siblings and a child alleging sexual abuse;


“The claim [presented by the claimant’s solicitors]…is arguable. The decision dated 23rd November 2011 is arguable based on errors of law and/or reasoning.”


Stephen Morris QC sitting as Deputy High Court Judge – 28th June 2012 




Referring to the detailed evidence in our bundle preparation…


“A plethora of evidence was submitted…”




“The Respondent did not have the power to dispose of an application in such a way. Returning documents deemed not to be sufficient evidence of Treaty rights in essence amounts to an EEA decision but bypasses the right of appeal under Regulation 26.” 


Referring to (and agreeing) with our submission in the Grounds of Appeal (and described orally in proceedings as “innovative”) that the Home Office practice of administratively returning EEA applications on account of insufficient evidence but falling short of making an “EEA decision” in order to bypass the right of appeal in Regulation 26 of the EEA (Imm) Regulations 2006,  is unlawful (ultra vires), the Judge held the following against the backdrop of the Supreme Court’s decision on “ancillary administrative powers” in R (on the application of New London College Ltd) v Secretary of State for the Home Department [2013] UKSC 51;


Judge of the First-tier Tribunal Turquet on 16th June 2014 




“The grounds [submitted by Douglass Simon Solicitors] complain, arguably rightly, that the respondent’s decision to refuse the application and her daughter leave to remain has not been considered properly.” 


Referring to detailed Grounds of Claim on a Judicial Review involving considerations of the child’s best interests under section 55 of the BCIA 2009


Upper Tribunal Judge Perkins considering Grounds of Claim on the papers in relation to an application for permission to apply for Judicial Review on 5th June 2014




On oral submissions made at a hearing by reference to grounds of application


“…a series of energetic submissions made…”


On oral submissions made at a hearing by reference to grounds of application


Upper Tribunal Judge Peter Lane in relation to an application for permission to apply for Judicial Review (renewal hearing) on 8th May 2014





“The applications were submitted with detailed representations and submissions.”




“The notices of appeal are supported by grounds which run to 30 pages which I have read and considered. The grounds particularly stress the unfairness which the first appellant has suffered by virtue of the restrictions which were introduced and which prevented her from making an application as a Tier 2 migrant…”


Judge of the First-tier Tribunal Hanley sitting in the First-tier Tribunal (determination promulgated on 14th April 2014) in allowing an appeal which involved human rights factors arising from shortages in the care industry and the historical wrong of operating a system (a Shortage Occupation List) which was ultra vires section 3(5) of the Immigration Act 1971 (as amended) to include considerations on whether the Secretary of State fettered his own policy – the ‘Alvi policy’ conceived in July 2012





“…a good arguable [claim] for both claimants is revealed.”


HH Judge Anthony Thornton QC sitting as a judge in the High Court (Administrative Court) on 14th April 2014 in relation to an application for permission to apply for Judicial Review submitting by Douglass Simon Solicitors (Lira Simon Cabatbat and Fadi Farhat)





The representations went on to weave a rich tapestry of argument, ranging from Aristotle to Lord Mersey, to the effect that there was space for the application to succeed within the broad conception of family and private life notwithstanding the difficulties it faced under Appendix FM... Very extensive supporting evidence was supplied with the application.”



Immigration Judge M Symes in the First-tier Tribunal on 3rd January 2014 in allowing an Appeal which involved consideration of Paragraph EX.1 of Appendix FM, Human Rights and other discretionary factors.  





“…very detailed, addressing each point of the Refusal in turn….a key ingredient in the amended grounds of appeal is that the Appellant is treated as a member of Mr. Hellel’s family and consequently is exempt from the National Minimum Wage requirements; reference is made to various policy and guidance documents.”


First-tier Tirbunal Judge R Sullivan on 15th October 2013 in allowing an appeal on the papers following written submissions which applied the Court of Appeal’s ruling in Nambalat v Taher & Anor [2012] amongst other references to the case-law and policy 





“I hope I do Mr. Sowerby’s [Barrister] submissions no disservice if I say that they did not materially add to the detailed and helpful grounds of appeal [prepared by instructed Solicitors].”



Upper Tribunal Judge Moulden – 12/07/2013 – on an appeal which involved consideration of the Home Office’s policy on ‘evidential flexibility’





“If [the facts] are as asserted [by the appellant’s solicitors]…it is arguable that the decision was infected by a serious want of fairness”  



Lord Justice Laws in the Court of Appeal granting permission pursuant to the second appeals test under Upper Tribunal Order 2008 (SI 2008/2834)




On grounds of appeal submitted in relation to Articles 8, 6 and 12 of the ECHR;
“It is the most learned pleading I have ever seen….it is a very serious document.”

Immigration Judge Blake in the First-tier Tribunal on 2011





On an application for Judicial Review before the Administrative Court
“….the detailed grounds of claim…display a good knowledge of human rights and immigration law….”

Mr. Justice Mitting in the Administrative Court (CO/7179/2010) – 29/06/2010




"In well crafted grounds of appeal prepared by the appellant's solicitors [Douglass Simon]….the representatives were alert to the substitution of that paragraph by HC439"



Immigration Judge M. B. Hussain in the First-tier Tribunal – 28/03/2011





“The…evidence [provided by the appellant’s representative] is most comprehensive….it is carefully set out…”



Immigration Judge JR Devittie in the First-tier Tribunal – 25/01/2011





"I find that the reasons given by the respondent for refusing the appellant's application lack any substance and that the same have been adequately and satisfactorily addressed by….the appellant's representative in the grounds of appeal…"



Immigration Judge Pedro in the First-tier Tribunal – 05/08/2011




"Detailed grounds of appeal were prepared amounting to 14 pages of the appellant's bundle….an attempt to explain how this could be made in an entirely innocent way: it is described in the grounds of appeal as a "mistake of technical abstract"…"



Immigration Judge Ferguson in the First-tier Tribunal – 27/10/2011




In dismissing an appeal by the Secretary of State in the Upper Tribunal "….as clear as day that these grounds [by the Secretary of State] are misconceived and should not have been submitted"


Upper Tribunal Judge Kopieczek – 21/11/2011





"The Appellant's solicitors have set out at some length and with great force the arguments and the law….I agree with [them]…"



Immigration Judge Graham Campbell in the First-tier Tribunal – 14/12/2011




In allowing an appeal on a Tier 2 Points Based System matter "….Grounds of Appeal submitted on his behalf by his solicitors, Douglass Simon…are set out over thirteen pages of typescript in which a forceful argument is developed against the respondent's decision.


Immigration Judge Sharp of the First-tier Tribunal – 10/01/2012




"There is…a detailed review of the law…in some considerable detail…"


Immigration Judge Sharp of the First-tier Tribunal – 10/01/2012




"It is also clear from the case-law in relation to the CCOL…to which Douglass Simon referred in the covering letter to the application that the mere obtaining of the CCOL certificate should not give rise to a mandatory refusal….[in agreeing with Douglass Simon's submissions]…there is a complete lack of reasoning in the refusal notice as to why the Respondent chose to refuse this case…"


Judge of the First-tier Tribunal Randall – 30/01/2012





“The appellant’s solicitors have submitted Grounds of Appeal. It is very detailed…the relevant parts are indeed very illuminating.”

Judge of the Firs-tier Tribunal NMK Lawrence – 07/02/2012 (In relation to the policy classification of "graduate level" jobs within Tier 2 of the PBS)





“The [well-written] lengthy grounds seeking permission to appeal challenged the interpretation of the Rules and the Article 8 findings on 5 separate grounds.”  

Upper Tribunal Judge Coker- 13/03/2012





"The grounds dated 26th March 2012…are well argued and argue, inter alia, that Shahzad (s85A: commencement) [2012] UKUT 81 (IAC) applies. That may well be so…All grounds may be argued."

Designated First-tier Tribunal Judge Manuell – 03/04/2012




"The appeal was [well] and realistically therefore argued [by the Appellants' solicitors] relying on the impact on return…."

Immigration Judge Shamash – 04/05/2010




“…ingenious argument…”

Designated First-tier Tribunal Judge Manuell – 22/05/2012 (In relation to a legal argument present to the Tribunal on a point of construction)





“…full and detailed…”

First-tier Tribunal Judge O'Garro – 26/04/2012 (In relation to the submitted grounds of appeal before the Judge)





What Clients say...


“Harry Khan has recently carried out work for me with services rendered impeccably. Harry's performance was outstanding, he made me feel totally safe and secure whilst providing me with a high standard of customer service, he was diplomatic, kind and his sincerity as a business man could not be faulted. I would highly recommend him and his team to any one that required this service and I would undoubtedly want to use his services again if and when I require a solicitor. Harry’s people skills are successful as he has made an effort to inform me on all matters concerned in my case. Harry has also successfully delegated work to other members of his team, whilst maintaining high standards of qualitative leadership skills. Harry is a credit to your company and his continued enthusiasm is a delight.  I am very grateful for his input and knowledge and I wish him every success with all business deals and may his career be a happy and rewarding one.”


R.M – Probate (Inheritance Act Claim)



“I am writing this email to say I am very satisfied with the work done by Mr Haroon Khan.  In the past few months I had to deal with various solicitors from different firms and none of them compared to the service I received at Douglass Simon.  This was the only place where my situation was thoroughly explained as well as my options. I have received prompt response whenever I had my further questions.”



I.  S. S. L.  - Immigration Client



“Dear Ms Cabatbat,....I would like to say thank you for all your hard work and for pushing the Home Office to make the correct decision in our case.  We very much appreciate this, you have been very good to us”.   


M. B. R – Immigration Client


“To Mr Khan, thank you for dealing with us with so much kindness and professionalism.” 


P. & G. D. - Probate Clients


“...Very happy with the service and I would be happy to recommend Douglass Simon Solicitors.”


A.    S. – Matrimonial Client


“I was extremely impressed with the help and advice I received; the intelligence in dealing with my particular case helped me through a difficult time. The standard and professionalism of Ms Cabatbat has been extremely high – Douglass Simon is an exceptional law firm.”


Mr & Mrs C. – Immigration Client


“Thank you so much for everything you have done for me.  The service you provided was exceptionally good and you have been very fair with me about fees.”


S. D.  - Employment Client


 “We received good and prompt service”


P. M. G – Family Client


“Mr Khan has dealt with my immigration matter a few times now and he is excellent.  I was happy with the service from start to finish.  One thing that was excellent was that when I phoned for quick updates Mr Khan always took my calls.”


M. B. – Immigration Client 


"The service was excellent throughout.  Just to say the service from Sandeep Barham was excellent.  Many thanks for what was a difficult process.”


S. R. – Matrimonial Client


“We changed to Douglass Simon following a poor service from our previous solicitors.  The service we received from yourselves was outstanding.  Lira Cabatbat was extremely helpful and assisted with my case fantastically and with a fairly short timescale as we had been let down by a previous solicitors service.”



V. C. S. T – Immigration Client


"…thank you for your help.  We always felt you were 'on our side' through all negotiations which is all the client wants."


T. P. – Matrimonial Client


"Over the past 18 months Mr Khan assisted in a variety of employment matters. At all times he was professional, reliable and informative. His advice and action would be robust when necessary but always willing to consider a pragmatic approach or take on board wider commercial objectives. I would have no hesitation recommending Mr Khan’s services on any employment matter."


P & T Ltd – Employment Clients





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We appreciate that legal services are about people and as experts in our field we pride ourselves in giving practical, concise advice.  For over fifteen we have consistently provided a high standard of

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