Testimonials

“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.”

“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. “

and

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

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

and

“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….”

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

“…the decision is subjected to detailed analysis…”

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

“As [the] grounds make clear…”

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

“The notice of appeal was accompanied by detailed submissions by the Appellant’s solicitors which I have read…
I agree with [their] analysis…”

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

“A plethora of evidence was submitted…”

and

“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.”

“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.”

“…a series of energetic submissions made…”

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

and

“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…”

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

“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.”

“…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 [the employer’s] family and consequently is exempt from the National Minimum Wage requirements; reference is made to various policy and guidance documents.”

“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].”

“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”

“It is the most learned pleading I have ever seen….it is a very serious document.”

“….the detailed grounds of claim…display a good knowledge of human rights and immigration law….”

“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”

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

“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…”

“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”…”

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”

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

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.

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

“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…”

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

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

“The grounds …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.”

“The appeal was … realistically therefore argued [by the Appellants’ solicitors] relying on the impact on return….”

“…ingenious argument…”

“…full and detailed…”