Nigel Hollinworth v The Valuation Tribunal for England & Wakefield Met District Council, Billing Authority

Neutral Citation Number: [2026] EWHC 1149 (Admin) Case No: AC-2025-LON-004292 IN THE HIGH COURT OF JUSTICE KING’S BENCH DIVISION ADMINISTRATIVE COURT Royal Courts of Justice Strand, London, WC2A 2LL Date: 14/05/2026 Before: THE HONOURABLE MR JUSTICE SWEETING – – – – – – – – – – – – – – – – – – – – – Between: Nigel HOLLINWORTH Appellant – and – The VALUATION TRIBUNAL for England & Wakefield Met District Council, Billing Authority Respondent – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – – The Applicant appeared in person. The Respondent did not attend. Hearing dates: 3rd March 2026 – – – – – – – – – – – – – – – – – – – – – Approved Judgment This judgment was handed down remotely at 11.30am on 14.05.2026 by circulation to the parties or their representatives by e-mail and by release to the National Archives. ……………………….. THE HONOURABLE MR JUSTICE SWEETING Mr Justice Sweeting: Introduction

1. These proceedings arise from two appeals brought by Mr Nigel Hollinworth (“Mr Hollinworth” or “the Appellant”) before the Valuation Tribunal for England (“the Tribunal”) concerning his liability to pay council tax in respect of a dwelling in Wakefield. The underlying issue before the Tribunal was whether, for the purposes of section 6(2)(a) of the Local Government Finance Act 1992 (“LGFA 1992”), the Appellant was a “resident” of the dwelling from 15 June 2016 onwards.

2. The Appellant is a litigant in person. I granted his application to have help from a “MacKenzie friend”, Mr Adam Rafal, at the hearing. I should record that Mr Rafal was well prepared and properly limited his participation in the proceedings to assisting the Appellant.

3. The correct Respondent to the appeal is the City of Wakefield Metropolitan District Council (“the Council” or “the Respondent”). The Council was not represented at the hearing. The Tribunal itself, as is conventional, did not make any representations. Background

4. The Appellant retired from employment with the Council in 2014 and moved abroad. He says that since 2014 he has lived outside the United Kingdom and presently resides in Spain. The billing authority (the Council) initially treated him as resident abroad and not liable for council tax. With effect from 15 June 2016, it determined that he was an owner‑resident of Priory Cottage, Pontefract Road, Pontefract, and therefore liable for council tax in respect of a chargeable dwelling. The Appellant commenced the statutory appeal procedure and served a written notice on the Council under section 16(4) of LGFA 1992. The Council gave a timely response under section 16(7)(a) rejecting the grievance on 17 May 2019.

5. Two Tribunal appeals followed. The first appeal concerned the period from 15 June 2016 onwards. It was lodged in August 2019 but was out of time. An application for an extension under Regulation 21(6) of the Valuation Tribunal for England (Council Tax and Rating Appeals) (Procedure) Regulations 2009 (“the 2009 Regulations”) was refused in October 2019, so that the appeal was not accepted. The second appeal was lodged on 29 December 2019 and concerned the 2019/20 billing year alone (1 April 2019 to 31 March 2020). This appeal was accepted for determination after a delay of 5 months.

6. Thereafter the matter was marked by delay and listing difficulties. The second appeal hearing was listed for 9 June 2022 with “Standard Directions” mirroring the Tribunal’s “Practice Statement 11 – Disclosure in all council tax appeals” (“PS11”), which required the Appellant to send any further information to the Respondent four weeks before the hearing, to state the change sought and the relevant dates. In accordance with those directions, on 12 May 2022 the Appellant served (i) written submissions and (ii) an evidential bundle. The June 2022 hearing was cancelled on 8 June 2022; a subsequent hearing listed for 24 November 2022 was cancelled, shortly before it was due to begin, when the Tribunal identified a preliminary jurisdictional issue.

7. In January 2023, the Tribunal revisited the position on the first appeal. On 18 January 2023, following a review under Regulation 40 of the 2009 Regulations, the Tribunal’s President set aside the earlier refusal to admit the first appeal as out of time, describing that outcome as a “miscarriage of justice”. The President accepted the first appeal and directed that the two appeals be listed together, noting that the second appeal was, as a result, “largely superfluous”. He confirmed that the Tribunal had jurisdiction to determine whether the Appellant was liable for Council Tax “from 15 June 2016 onwards”.

8. The Appellant applied, on 7 February 2023, for directions, requiring the Tribunal to implement PS11 in the first appeal, so that (a) the parties could exchange evidence in accordance with the four‑week timetable and (b) he could specify the dates in dispute. A hearing listed for 22 February 2023 was vacated on 17 February 2023 to enable determination of that application. For reasons which are unexplained there was no determination of Appellant’s application for directions or a relisting of the appeal until 2025.

9. In early 2025, the Tribunal listed a hearing for 11 February 2025. This prompted a letter from the Appellant on the 24 of January 2025 in which he informed the Tribunal that unless it adjudicated on his application for directions, which had been outstanding for two years, and postponed the trial to enable compliance with the Tribunal’s own practice statement he would apply for judicial review and seek an injunction.

10. On 4 February 2025, five days before the hearing date, the Tribunal refused the Appellant’s outstanding applications and made directions expressly disapplying its standard directions. The Appellant says this left him without the opportunity, afforded by the directions, to lodge updated evidence four weeks in advance or to specify the operative dates, notwithstanding the prior delays. The hearing proceeded on 11 February 2025 and on 14 February 2025 the Tribunal dismissed the Appellant’s appeals. However, it only adjudicated in relation to the period from 15 June 2016 to 30 June 2022. The Appellant says that this latter date was simply plucked out of the air, has no relevance to any aspect of his appeal and is unexplained. Moreover, he submits, it is not a determination of his liability from the 15 June 2016 “onwards” and would not have been a date he would have selected had the standard directions been followed.

11. The Appellant did not attend the hearing on 11 February 2025, having on the previous day served both a judicial review claim and an application for an injunction seeking to prevent the Tribunal from proceeding; in effect by requiring an adjournment. The Tribunal determined that there was no order preventing it from continuing and no reason to adjourn. It proceeded in the Appellant’s absence, reaching the conclusions now the subject of this appeal. The injunction application came before a Judge (Matthew Butt KC sitting as a Deputy Judge of the High Court) after the Tribunal hearing had concluded, so that the relief sought was academic. In his reasons for refusing relief, DHCJ Butt KC, although expressing sympathy for the Appellant, referred to the fact that he had not attended the hearing and addressed the Tribunal on the issue of outstanding evidence or an adjournment, as he could have done.

12. The Appellant subsequently pursued two judicial review claims issued on 10 February 2025 and 14 March 2025. Permission was refused in both, including after a renewal hearing before HHJ Walden‑Smith (sitting as a Deputy High Court Judge) on 2 October 2025. The Judge indicated on that occasion that the appropriate mechanism for a challenge was by way of statutory appeal, not judicial review. She extended time until 16 October 2025 for the Appellant to bring such an appeal. The Appeal

13. The Appellant’s pleaded grounds are not clearly expressed but based on the material before me and the equivalent grounds previously advanced in the judicial reviews, it is possible to formulate the following coherent statutory appeal grounds: Ground 1 – Procedural unfairness / breach of Article 6 ECHR in case management

14. It is said that the Tribunal acted unfairly in refusing the Appellant’s application (under Regulation 8 of the 2009 Regulations) to rely on further evidence of his residence abroad after May 2022, and by listing the hearing for 11 February 2025 without ensuring he could present such evidence. This is framed as an alleged denial of a fair opportunity to present his case. Ground 2 – Error of law / irrationality in refusing adjournment

15. The Appellant contends that the Tribunal’s refusal to adjourn the hearing was irrational and failed to take account of relevant matters, including his pending applications and his attempts to seek High Court intervention. Ground 3 – Failure to consider relevant evidence / inadequate inquiry

16. The Appellant asserts that the Tribunal either failed to consider, or was not presented with, material evidence he had lodged concerning his residence abroad, and that this led to an erroneous factual conclusion as to his “sole or main residence”. Ground 4 – Error of law in the substantive finding of residence

17. It is contended that the Tribunal’s finding that the Appellant was resident at the subject property from 15 June 2016 to 30 June 2022 was irrational, inadequately reasoned, and/or unsupported by a proper evidential basis. The Appellant says that the Tribunal failed to apply the correct two stage test for residence which required the Tribunal to consider where the Appellant resided and then, if there was more than one potential residence, which was his sole or main residence. He referred in support of this ground to Williams v Horsham District Council [2004] EWCA Civ 39, where at paragraph 26 of the judgment, Lord Phillips MR held: “All this reinforces the conclusion (which is one that we would have reached without reference to the dictionary) that in section 6(5) of the Act “sole or main residence” refers to premises in which the taxpayer actually resides. The qualification “sole or main” addresses the fact that a person may reside in more than one place. We think that it is probably impossible to produce a definition of “main residence” that will provide the appropriate test in all circumstances. Usually, however, a person’s main residence will be the dwelling that a reasonable onlooker, with knowledge of the material facts, would regard as that person’s home at the material time. That test may not always be an easy one to apply, but we have no doubt as to the conclusion to which it leads in the present case.” Ground 5 – Abuse of discretion / fettering

18. The Appellant contended that the Tribunal acted with an improper motive, or fettered its discretion, by failing to adjudicate the whole period in dispute. Reformulated, this amounts to an assertion that the Tribunal misdirected itself as to the scope of its jurisdiction or failed to determine relevant matters.

19. In summary therefore the Appellant contends that: i) the Tribunal unlawfully disapplied PS11, thereby denying him a fair opportunity to present his case; ii) his application of 7 February 2023 was not determined until 4 February 2025, five working days before the hearing, and he was afforded no meaningful opportunity to seek a variation or appeal the directions; iii) the Tribunal failed to adjudicate the entire period in dispute as identified by the President, determining only 15 June 2016 to 30 June 2022; and iv) material evidence was not presented to or considered by Tribunal.

20. Regulation 43 of the 2009 Regulations provides that the High Court may, on appeal, confirm, vary, set aside, revoke or remit the decision or order and make any order the Tribunal could have made. However, an appeal lies to the High Court only on a question of law arising out of a decision or order given or made by the Tribunal.

21. The Appellant seeks orders: i) Quashing the Tribunal’s decisions of 4 February 2025 and 14 February 2025. ii) Remitting the matter to be determined afresh for the entire period from 15 June 2016 onwards. iii) Compelling the Tribunal to apply PS11 and allow him to lodge evidence four weeks before the new hearing. Discussion and Conclusions

22. Mr Hollinworth’s submission to me at the hearing was that when his appeals were consolidated, they related to the determination of his liability to pay Council tax from 2016 “onwards” and that this related to the period up to the Tribunal’s determination in accordance with the procedure envisaged under PS11. I consider that that was a reasonable interpretation, on his part, of the order that was made by the Tribunal President and the intention behind the procedure in the Practice Statement which then applied.

23. Whilst it is true that the President’s practice note regarding postponements and adjournments states: “Where appeal is postponed after the parties have complied with some or all of the directions there is no need to replicate the requirements of a direction unless the parties have further evidence or argument to add to proceedings. Where that occurs application must be made to the tribunal” the Appellant had in fact made an application for directions in February 2023. There was not then a “postponement” or “adjournment” but a straightforward failure to determine the application and list the appeal.

24. An email from the Tribunal, later in 2023, indicated that a determination was still awaited, but after that the matter appears to have gone into the long grass and was only resurrected by the Tribunal on 4 or 5 December 2024 (not it appears at the request of the Respondent) when the substantive appeal was listed in February 2025, still without the Appellant’s application for directions having been dealt with. The Appellant pointed out to the Tribunal that it was outstanding (on 24 January 2025). He sought an adjournment of the substantive hearing so that directions could be given and complied with. The Tribunal Deputy Registrar confirmed by email on 29 January 2025 that the application would be progressed promptly given that “the relisting of the appeals has brought the application back to the fore”.

25. The decision of the Tribunal Vice President adjudicating on the applications is dated 3 February 2025. She observed that “Regretfully, it appears that the Appellant’s applications had fallen aside and have not been judicially determined”. She added “…the Appellant has (quite properly) requested the Tribunal determines that outstanding applications of the 7 February 2023.”

26. The Appellant sought directions under five separate heads, as follows: i) Disclosure in respect of the first appeal pursuant to PS11. ii) Production of documents by the Respondent under Regulation

18. iii) A pre‑hearing determination of legal principles and issues in dispute. iv) An order requiring the Respondent to confine or redact its evidence to matters said to be relevant to the period in issue. v) Additional time (up to two days) to be allocated for the hearing.

27. The Vice President accepted that no separate disclosure directions had been made in respect of the first appeal. She observed that “the Appellant is technically correct; the first appeal was listed without disclosure directions.” However, she found that full disclosure of evidence and submissions covering the entire disputed period had already taken place in the context of the second appeal, which raised the same substantive issue. The Appellant had in fact, she concluded, advanced arguments and evidence addressing his liability for council tax from 2016 onwards. There was therefore no requirement for further disclosure. Reliance on the absence of formal disclosure directions amounted to reliance on a technicality which did not assist the fair determination of the appeals. The disclosure application was therefore refused.

28. The range of documents sought by Mr Hollinworth included council tax bills and adjustment notices, correspondence referred to in an MP’s letter, and contemporaneous notes from a site visit. The Vice President determined that the requested billing and adjustment notices did not assist in deciding the issue of liability to pay tax and related merely to the history of billing decisions. The correspondence attached to the MP’s letter was correspondence originating from the Appellant himself and therefore material which he could have produced if relevant. The contemporaneous notes from the site visit were, she considered, unnecessary given that the Respondent had already provided its written conclusions and that the matter addressed was not central to the issue which had to be decided.

29. The Vice President rejected the application to determine legal principles and issues in advance of the hearing. She observed that the dispute was straightforward; the Respondent argued that liability to pay council tax arose on the basis that the Appellant was a resident freeholder, and the sole issue was whether the Appellant was “resident” within the meaning of section 6 of the 1992 Act. She did not consider that the applicable statutory test and legal authorities were opaque or in need of advance clarification, so that it was proportionate that matters of law and fact be addressed at the substantive hearing.

30. In so far as the Appellant had sought an order requiring the Respondent to remove or redact material said to be irrelevant, the Vice President determined that it was for the Tribunal, at the hearing, to assess the relevance and weight of the evidence adduced and that a pre‑emptive restriction on evidence was not justified.

31. The Vice President considered that two days would be an excessive allocation of time for an appeal of the nature advanced by the Appellant. She also rejected the application for an adjournment given that all applications had now been determined (against the Appellant). Bearing in mind the long‑running nature of the dispute she concluded that the interests of justice favoured proceeding to a final determination.

32. She made case‑management directions to ensure the appeals proceeded efficiently: i) The Tribunal’s standard directions were disapplied. ii) Both appeals were directed to be heard together, reserved to the Vice President sitting alone, at a remote hearing on 11 February 2025. iii) Liberty was granted to either party to apply to vary the directions, with any such application reserved to the Vice President.

33. Mr Hollinworth says that determining his applications in this way was unfair and unreasonable in the circumstances having regard to the delay which was not of his making. The Tribunal appeared to him to be acting with a haste which was not justified in the circumstances. Indeed, he went further suggesting that the ruling on his applications was expedient, tainted by an ulterior motive and taken so close to the hearing as to prevent any meaningful challenge.

34. A number of the Appellant’s applications were, in my view, always likely to be refused, whenever they were determined, and were in any event all squarely case management decisions with which this court should be slow to interfere. The reasons for appellate reluctance in this respect were set out by Lewison LJ when giving judgment in Broughton v Kop Football (Cayman) Ltd [2012] EWCA Civ 1743: “51. Case management decisions are discretionary decisions. They often involve an attempt to find the least worst solution where parties have diametrically opposed interests. The discretion involved is entrusted to the first instance judge. An appellate court does not exercise the discretion for itself. It can interfere with the exercise of the discretion by a first instance judge where he has misdirected himself in law, has failed to take relevant factors into account, has taken into account irrelevant factors or has come to a decision that is plainly wrong in the sense of being outside the generous ambit where reasonable decision makers may disagree. So the question is not whether we would have made the same decisions as the judge. The question is whether the judge’s decision was wrong in the sense that I have explained.”

35. The Vice President gave a reasoned judgment which does not disclose any error of law. Whilst I can understand why the Appellant has gained the impression that he had been treated unfairly, given that he was not at fault in respect of a long delay, there is nothing to indicate that the Tribunal was acting in bad faith. The question of whether there would be any unfairness if the hearing went ahead without the disclosure and further directions that the Appellant had requested was properly considered and rejected. The Vice President clearly came to the view that nothing would be gained by further delay, for the reasons she gave and based on the material before her.

36. The substantive hearing then took place without Mr Hollinworth attending because, he told me, he did not want to legitimise what he regarded as a procedurally unfair and unreasonable process. The Tribunal was entitled to proceed in his absence as long as it was satisfied that he had been properly notified and that it was in the interests of justice to proceed with the hearing.

37. In relation to the various procedural complaints that had been made (and determined in so far as they were applications) the Vice President said: “Firstly, the Appellant compares the disapplication of the standard directions with a court disapplying the Civil Procedure Rules (the “CPR”). This is plainly wrong. The Tribunal Procedure Regulations are the equivalent of the CPR in this Tribunal. The standard directions set out in PS11 of the Tribunal’s Consolidated Practice Statement (the “CPS”), as it stood in 2022 (it has since been updated and no longer applies to appeals of this type), simply provided the framework for the parties to disclose their respective evidence and submissions. It is not a straitjacket to bind the Tribunal. If the Tribunal is satisfied that the parties have had an opportunity to disclose their respective cases, as I was in my appeal management decision of 3 February 2025, then there is no reason why the Tribunal cannot adopt a different procedure in any case. Secondly, the Appellant contends that he has been unable to disclose any witness testimony or evidence since 12 May 2022. That is entirely correct. However, there has been no application to extend the scope of these appeals to include a period after June 2022 (as was requested by the Appellant in his written submissions of 12 May 2022). Given the delays to date, I believe that the interests of justice require the substantive dispute for the period currently before the Tribunal is be given prompt judicial consideration, and a final determination issued (if possible). A decision on the earlier periods may inform the parties positions in respect of any later periods that may fall to be disputed. But additionally, it cannot be the case that the period is repeatedly extended ad infinitum every time there is a delay (and thus a party requests a further opportunity for disclosure in respect of that extended period). It is better in my view to draw the line in the sand now and determine the substantive issue, at least for the period currently before the Tribunal. Thirdly, the Appellant has not applied to the Tribunal for permission to introduce further material. Considering the procedural backdrop, he appears misguided that PS11 of the CPS (again as it stood in 2022) would apply to every re-listing of the appeal. That has never been the case. The President’s Practice Notice regarding Postponements and Adjournments (VTE/PN/2017-1) makes that abundantly clear… Whilst I accept a significant period has, regrettably, elapsed since the parties last filed their submissions and evidence, I am wholly unconvinced that allowing further disclosure would assist the Tribunal with its task of determining whether the Appellant is resident at, and thus liable to pay council tax in respect of, the subject dwelling from 15 June 2016. There are already several bundles from both parties before the Tribunal, with a significant amount of duplicated material. Adding further opportunity for disclosure by the parties would undoubtedly, in my view, result in additional satellite litigation (whether in this Tribunal or in the High Court). These appeals require a final determination, not additional satellite litigation which will only serve to further delay the dispensation of justice. Fourthly, it is clear to me that the Appellant has chosen not to attend the hearing. He has been given every opportunity to participate, but has instead, has chosen to deprive himself of the opportunity to address the Tribunal directly with any oral submissions, or answer any questions from the Tribunal or the Respondent Billing Authority’s representative. I appreciate that he clearly believes the Tribunal is acting unlawfully by proceeding (hence his applications to the High Court), but for the reasons I set out at paragraph 20, above, I am not of the view that this should result in an adjournment: it is simply not proportionate. I am also conscious that I have comprehensive, and legally detailed, written submissions from the Appellant, setting out his arguments as to his grounds of appeal.”

38. I might have reached a different conclusion as to the utility of determining the residence position only up to 2022 given the delay and when the hearing was taking place. The determination was in relation to the Appellant's liability to pay council tax to the end of June 2022. It is not apparent what the significance of that date was other than that it marks the end of the first quarter in the financial year. I should add that Mr Hollinworth pointed out that the material which had been provided by him was limited in its scope so that for example the records relating to his travel, which he had obtained as a result of a subject access request in the pre-appeal process prior to 2019 when the appeals were launched, only referred to his travel up until 2018. By 2025 it would have been open to him to obtain further records which would have supported his overall argument.

39. Whilst the observation that there could not be a continually extending appeal process may have been apposite, it cannot, equally, be the case that the Council taxpayer has to launch further appeals after long delays for which they are not responsible. However, the issue was plainly considered by the Tribunal and a reasoned conclusion arrived at. The position was undoubtedly complicated by the Appellant’s voluntary absence from the hearing. The reasons given by the Vice President for the course she took do not, in my view, disclose any error of law.

40. The Tribunal went on to dismiss the appeal. It noted that: “…the strongest evidence upon which the Appellant relies are the records of his entries and exits obtained from UK Border Force. The records are slightly incomplete as there are some departures from the United Kingdom without preceding arrivals. However, what is available shows that between 31 March 2014 and 16 October 2018 the Appellant had spent only 53 days in the United Kingdom, which equates to 3.2% of the time. This rises to 4% when restricted to the period after 15 June 2016. The evidence suggests a nomadic lifestyle, indeed there is evidence that he travelled often, visiting Australia, France, Germany, Italy, Luxembourg, Spain, Switzerland, and Thailand.”

41. In her judgment the Vice President referred to the applicable legal test and ultimately considered that the Appellant’s own declarations, on at least three occasions, that the subject dwelling was his residence, was a determinative factor along with other evidence that the Respondent billing authority relied on to establish that the property was the Appellant’s home and main residence not withstanding his travels.

42. My conclusions so far are therefore fatal to most of the grounds advanced, but they do not entirely dispose of the appeal to this court.

43. On 12 May 2022 the Appellant had complied with paragraph one of the Tribunal’s standard directions and filed and served two PDF documents which were, 9 pages of submissions and a 237-page bundle of documentary evidence. The Appellant’s 2022 bundle of documents was received by the Tribunal and acknowledged. When it came to the 2025 appeal hearing the Tribunal administrative staff, rather than the Council, provided a bundle of the material which was to be placed before the Tribunal which, the Appellant submitted, was itself a departure from the rules set out in the practice regulations. On 4 February 2025 the Tribunal wrote to the parties by email saying: “Please find attached a copy of the evidence that will be presented to the panel at the hearing of this appeal on 11th February 2025.”

44. The PDF file attached to that email, entitled “evidence”, is 292 pages in length.

45. When Mr Hollinworth subsequently received the decision, he told me that he realised immediately that none of the material that he had sent to the tribunal in relation to his second appeal was referred to. The decision, he submitted, appears to have been taken entirely on the material which had been lodged by the Respondent billing authority albeit that it contained the earlier correspondence and submissions which he had provided to the council. What was omitted, he suggested, were the hundreds of pages of material which he had sent to the Tribunal in May of 2022. This included documents which evidenced his residence in Spain and would on their face appear to have answered some of the rhetorical questions posed by the decision maker in relation to the lack of evidence. Mr Hollinworth was able to demonstrate in his submissions why it could be inferred that the Tribunal had not had all of the relevant material before it.

46. Although the Vice President’s decision refers to “several bundles from both parties” with “a significant amount of duplicated material” I am not, given the procedural background, prepared to assume that all of the documents had been properly collated. As Mr Hollinworth submitted, any such assumption would require confidence in the procedural administration of the appeal which he had good reason to question. In any event the Tribunal’s email of 4 February 2025 was to be taken at face value as indicating what evidence was to be considered. He explained in his submissions why he had not looked at the attachment to identify any omissions. He was not asked to do so, and it does not appear that the council did so either. He had already, years previously, complied with his obligations under the Practice Statement and receipt of his evidence had been acknowledged by the Tribunal. He suggested that the long delay and the contrasting alacrity with which the hearing was eventually listed had led to error and was another example of how he had been prejudiced by an elapse of time for which he was not responsible.

47. The overall position appears to be that after a long and unexplained delay on the part of the Tribunal, the Appellant’s long outstanding application to provide further material was refused, the normal procedural steps were set to one side and the appeal proceeded directly to a hearing omitting consideration of the evidence which the Appellant had filed with the court over two years earlier. A failure to take into account all relevant material submitted for the hearing would plainly be an error of law notwithstanding that it was inadvertent. I am not in a position to exclude the possibility that the missing material would have altered the outcome since it was potentially relevant to the central issue which the Tribunal had to determine.

48. In those circumstances, the appropriate course is to set aside the decision and remit to the Tribunal for a rehearing with a direction that there should be case management hearing to give directions for the hearing of the appeal and that those directions should allow for the submission of further and updated material in relation to the Appellant’s liability to pay Council Tax from 2016 onwards. The appeal is therefore allowed. END