Exercising discretion when applying to the court for a Council Tax Liability Order

Helen Barker made this Freedom of Information request to Blaby District Council

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Dear Blaby District Council,

The Council Tax (Administration and Enforcement) Regulations 1992 (the "Regulations") confer a duty on the billing authority to exercise discretion under regulation 34(1) when deciding whether to institute a complaint to the Magistrates' court to enforce payment.

Regulation 34(1) as amended by Regulation 15 of SI 1992/3008 states, with the relevant part emphasised, as follows:

"If an amount which has fallen due under paragraph (3) or (4) of regulation 23 (including those paragraphs as applied as mentioned in regulation 28A(2)) is wholly or partly unpaid, or (in a case where a final notice is required under regulation 33) the amount stated in the final notice is wholly or partly unpaid at the expiry of the period of 7 days beginning with the day on which the notice was issued, THE BILLING AUTHORITY MAY, in accordance with paragraph (2), apply to a magistrates' court for an order against the person by whom it is payable."

Regulation 34(2) states as follows:

"The application is to be instituted by making complaint to a justice of the peace, and requesting the issue of a summons directed to that person to appear before the court to show why he has not paid the sum which is outstanding."

The following are examples (but by no means exhaustive) of what are reasonable factors a recovery officer should take into account in exercising discretion to institute a complaint to the Magistrates court under paragraph (2) of regulation 34 of the Regulations:

1. the level of debt outstanding

2. any payments made subsequent to the full amount becoming due and time remaining of the financial year

3. are circumstances indicative of the debt being settled without resorting to enforcement

4. consider if enforcing the debt would unnecessarily subject the taxpayer to additional costs etc. and therefore amount to a penalty (see 3 above)

5. ensure monies have been prioritised to maintaining the in-year debt

6. allocate to the in-year any monies posted to arrears (or sufficient of it) that would if it had not been misallocated prevented the in-year liability also falling in arrears (see 5 above)

7. check for benefit claims or appeals already in the system and refrain from taking enforcement action where such genuine cases are unresolved

Q1. Does Blaby District Council exercise discretion before proceeding under regulation 34(2) of the Council Tax (Administration and Enforcement) Regulations 1992 to request a summons from a justice of the peace (it may be an automated process)

Q2. If yes to (1) what factors are taken into consideration

Yours faithfully,

Helen Barker

Freedom of Information Mailbox, Blaby District Council

Dear Helen,

Freedom of Information Request – FOI-20-449

I acknowledge your request for information received 17th April 2020

** We are currently working with limited resources and therefore it may not be possible to respond within the usual timeframes, however we will do our best to respond as soon as possible **

Your request is being considered under the Freedom of Information Act 2000 (“the Act”) and will be responded to within 20 working days, as defined by the Act. This is subject to the information not being exempt or containing a reference to a third party.

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Yours sincerely,

Emily Henderson
Information Governance Officer
Blaby District Council
[email address]

Telephone: 0116 272 7592
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Freedom of Information Mailbox, Blaby District Council

Dear Helen Barker,

Freedom of Information Request – FOI-20-449

Please find enclosed a response to your request for information, which was received on 17/04/2020, and has been dealt with under the Freedom of Information Act 200 (“the Act”).

Q1. Does Blaby District Council exercise discretion before proceeding under regulation 34(2) of the Council Tax (Administration and Enforcement) Regulations 1992 to request a summons from a justice of the peace (it may be an automated process) Yes

Q2. If yes to (1) what factors are taken into consideration All of the above and each case is reviewed on a case by case basis by the officers.

The information provided in response to Freedom of Information requests is subject to copyright protection. Where the copyright is owned by Blaby District Council, re-use is permitted in accordance with the terms of the Open Government Licence. However, we do ask that you attribute the information to Blaby District Council when re-using it.

Where third party copyright is identified, you will need to contact the copyright owner directly should you wish to re-use their information.

Should you be unhappy with the way your request has been handled you can ask for an internal review by emailing: [email address]. The Legal and Information Governance Officer will then arrange a review of your case.

If you are not happy with the outcome of the internal review, you have the right to apply directly to the Information Commissioner for a decision. For more information, please visit: www.ico.org.uk.

If you have any further queries, please email [email address] quoting the above reference number.

Yours sincerely

Information Governance Team, Blaby District Council

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Dear Freedom of Information Mailbox,

Thank you for your response.

The Council’s website indicates that discretion is not exercised at the point where a decision is needed to be made about whether to request a summons. Discretion is applied earlier than this, after a summons has been issued but before a liability order is obtained and after a liability order has been obtained.

So no discretion is exercised when requesting the issue of a summons and the procedure is effectively automated (the defendant incurs a £55.50 sum for that action). However, that sum actually covers the council's additional expenditure in respect of officer time engaging with customers who choose to query their accounts to arrange payment plans which would be conditioned upon the council obtaining a Liability Order (to secure the debt) adding a total £75.00 court costs comprising summons costs of £55.50 plus a further £19.50. This sum (£19.50) is added to the £55.50 costs already incurred for the request of the summons in respect of the accounts of all customers who have not paid the total amount outstanding of their liability, whether choosing to query their accounts or not. This is presumably to compensate the council for the officer time attributed to dealing with customers (in respect of those who contacted them) and making the application for a Liability Order (on day of the hearing).

Although its possible for a customer to avoid potential summons costs, for example, when a taxpayer who is struggling to pay contacts the Council and arranges a payment plan before the summons stage. Discretion whether to enter into a payment agreement with a taxpayer is applied again once the council has obtained a liability order (as an alternative to taking recovery action) but of course by that time she will have had the total £75.00 court costs added to the debt and included in the payment plan.

So the costs in reality cover as well as the expenditure already described the council's additional expenditure both before the summons is requested and after the liability order has been obtained in respect of officer time engaging with customers who agree to enter into payment arrangements.

Information obtained from the council's website also suggests what would be valid defences against the issue of a Liability Order at the court hearing and what are not valid defences. However, there are six obvious additional defences that would be valid if no discretion is exercised prior to requesting the issue of a summons and expenditure incurred by the council both before and once the summons has been issued are included in those costs. They would be that;

1. the billing authority has not (does not) comply with regulation 34(1) of the Council Tax (Administration and Enforcement) Regulations 1992;

2. expenditure amounting to £55.50 was not incurred by the council in respect of instituting the complaint;

3. the costs have been inflated to subsidise customers who elect to query their accounts, make payment arrangements, etc.;

4. the costs in respect of instituting the summons include expenditure which is incurred by the council after that action;

5. the costs have been inflated to subsidise expenditure incurred by the council in respect of potential applications to the court but which are not made by virtue of negotiations that have taken place; and

6. the costs in general have been inflated to subsidise expenditure incurred by the council in respect of officer time monitoring arrangements and/or engaging with customers after the process of applying for and obtaining the liability order has ended.

I would appreciate the council reviewing my request and confirming that the response to my request is "No" to (Q1) and therefore "N/A" in respect of (Q2).

Yours sincerely,

Helen Barker

Freedom of Information Mailbox, Blaby District Council

Dear Helen Barker,

Freedom of Information Request – FOI-20-486

I acknowledge receipt of your request for an internal review of the response to your Freedom of Information request.

The Council’s handling of your request will now be reviewed by a senior officer who was not involved with the initial request for information. We aim to respond as soon as possible and within 20 working days of receiving your request. In exceptional cases, we may extend the this timeframe, but we will notify you if this is the case.

In the meantime, if you have any further questions, please do not hesitate to contact me, quoting the above reference number.

Yours sincerely

Kind Regards,

Andrew Hickling Legal and Information Governance Officer
0116 272 7558

VISIT OUR WEBSITE: www.blaby.gov.uk

 Please save paper and only print out what is necessary

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Freedom of Information Mailbox, Blaby District Council

Dear Ms Barker

FREEDOM OF INFORMATION REQUEST REVIEW

I write further to your email of 5 May 2020, requesting an internal review of the decision of Miss Henderson (dated 4 May 2020) relating to Council Tax Regulations.
I have conducted the review in accordance with the Council’s policy which can be found at
http://www.blaby.gov.uk/about-the-counci...
I have also considered the following:
- Your original request email dated 17 April 2020
- The council’s response dated 4 May 2020
- Your request for an internal review dated 5 May 2020
- The council’s Information Management Policy
- The Freedom of Information Act 2000
- Section 45 Code of Practice Part VI for completing internal reviews

The Freedom of Information Act 2000 is relevant in relation to your request to view information relating to Council Tax Regulations.

I have now completed the review of your recent Freedom of Information Request, our reference FOI-20-486. I would first like to confirm that I was not involved in the handling of your original request and have undertaken a full re-evaluation of the case.

In your request for an internal review, you asked the council to amend their to response to “No” to Q1, and also amend the response to “N/A” in respect to Q2.

Having reviewed the request, I have concluded that the original decision was correct and that the information provided to you remains the same.

Our web pages do not reflect the comments made in your original request, and I have included a link below for your reference.

https://www.blaby.gov.uk/council-tax/pay....

If you are dissatisfied with the handling of your internal review, you have the right to ask for a decision by the Information Commissioner. For more information please visit www.ico.org.uk or write to the address shown below.

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 SAF

Please remember to quote the reference number given at the top of this letter in any future communications.

Yours sincerely

Andrew Hickling

Legal and Information Governance Officer

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Dear Freedom of Information Mailbox,

Please note your website publishes this information leaflet:
https://www.blaby.gov.uk/media/2532/summ...

Questions and answers include the following:

"Will you still get a Liability Order against me if I make an arrangement to pay?

We will still ask the Court for a Liability Order but will take no further enforcement action as long as you pay as agreed with the Council."

For your information, the costs of arranging a payment plan and subsequent monitoring of it are incurred at a point after the customer has tendered payment. Therefore, the cost attributable to this activity could not lawfully be included in the costs claimed because expenditure may only be recharged that has been incurred by the authority up to the time of the payment or tender and clearly resources called upon by engaging staff in the matter would occur after payment was tendered. Expenditure incurred by the authority after that point falls on the wrong side of line to be referable to the summons and would only be lawfully recharged (if eligible) in respect of those who had not paid or tendered to the authority the aggregate of the outstanding amount and costs before the court hearing because only those customers may be proceeded against further and incur additional costs.

To be clear, it is not just the costs in these circumstances which are artificially inflated by either front loading or being charged where there is no legal basis at all which is the issue. The consequences are that for all those cases against whom the council proceeds in order to secure the debt once an amount has been agreed (the payment arrangement), the action is unlawful because regulation 34 of SI 1992/613 provides that the authority shall accept the amount and the application shall not be proceeded with in these circumstances.

Paragraph 34(5) of the regulations, are as follows (with emphasis):

“(5) If, after a summons has been issued in accordance with paragraph (2) but before the application is heard, there is paid or TENDERED to the authority an amount equal to the aggregate of—

(a) the sum specified in the summons as the sum outstanding or so much of it as remains outstanding (as the case may be); and

(b) a sum of an amount equal to the costs reasonably incurred by the authority in connection with the application UP TO THE TIME OF THE payment or TENDER,

the authority shall accept the amount and the application shall not be proceeded with.”

The authority could not defend its actions on the grounds that an arrangement does not constitute payment therefore it is entitled to obtain a liability order to secure the debt because the law does not say that the amount must be paid for the application not to be proceeded with, only that the amount tendered is accepted (the aggregate of the outstanding amount and costs). By agreeing a payment plan which encompasses the outstanding amount and costs (costs which are properly referable to the enforcement process) the authority has accepted the amount and so there is no legal basis to proceed to obtain a liability order from the Magistrates' court.

Yours sincerely,

Helen Barker

Dear Freedom of Information Mailbox,

Since I submitted my review request a number of anomalies have come to light regarding the enforcement procedure in the area concerned. However, I do not wish to pursue this, though the council might want to reconsider its actions regarding the recovery of Council Tax in light of the issues. Note the issues raised in my 28 May email and reiterated here under the heading 'NO LEGAL BASIS TO PURSUE LIABILITY ORDER ONCE AN AMOUNT AGREED' the point discussed is not a discretionary matter. I suggest this and the other points raised are considered by the Monitoring Officer, but that is of course a matter for the council.

Further to my 5 May email it is evident that discretion is not exercised at the point where a decision is needed to be made about whether to request a summons but rather at the other stages mentioned and consequently the costs must with absolute certainty cover the general administration of the council tax and enforcement departments.

RELEVANT LEGISLATION AND CASE LAW

I understand that the council must adhere to the Council Tax (Administration and Enforcement) Regulations 1992 and also be mindful of all established case law regarding the area concerned.

I am aware of a number of cases but particularly three which I would like to refer to regarding your response namely R (Nicolson) v Tottenham Magistrates [2015] EWHC 1252 (Admin); Regina v Highgate Justices ex parte Petrou [1954] 1 ALL ER 406 and Williams v East Northamptonshire [2016] EWHC 470 (Admin).

Regina v Highgate Justices ex parte Petrou [1954] 1 ALL ER 406

The council's approach in treating customers differently regarding arrangements and the application (or not) of costs etc., implies that the liability order application process is exploited as a means of encouraging a change in behaviour because of the suggestion that a customer's circumstances/ payment history can influence a decision whether or not to allow the outstanding amount to be paid by instalments when the entitlement to has been lost. Presumably a customer whose payments are usually made on time will be given favourable consideration regarding a decision to allow them to continue with instalments (potentially avoiding enforcement and costs). A decision like this in these particular cases suggests that pursuing court action would not be the proper use of discretion because the circumstances indicate that the debt would be settled without resorting to enforcement. However, in a wider sense, because of the discrimination generally between customers who are considered prompt payers and those who are not, the decision to enforce regardless of whether it is necessary in respect of the latter suggests that the enforcement process is exploited for an improper purpose, i.e. to penalise the customer with the costs of enforcement.

It is likely that the council would prefer not to have to pursue payment by the various recovery methods permitted by the liability order because it would be more convenient and cause less administration not to and in any event, the chances of the whole amount being recovered would be greater (and quicker) if Enforcement Agents acting for the Council were not first having to be paid their enforcement fees. Whether the recovery action is pursued and costs imposed hinges on how the customer engages with the council and the type of debtor the council perceives the customer to be who has defaulted on payment. Pursuing recovery in some cases but not others suggests that rather than enforcement being necessary and the most appropriate course of action in every case, the costs of the court application are exploited to act as a penalty.

The law makes no provision for one party wishing to make use of the court to do so in order to inflict a penalty on the other by way of the costs which the court may order against the defendant. The judgment in the Highgate Justices case held that costs should not exceed the proper expenditure incurred and should not be a penalty. If the council requires further powers to enforce the debt, the court's permission must first be obtained, so the costs are incurred as a consequence, rather than the purpose of the application. Local authorities which exploit the judicial procedure to act as a deterrent in a way that penalises the defendant or to act as a threat to encourage prompt payment are doing so for an improper purpose.

Williams v East Northamptonshire [2016] EWHC 470 (Admin)

The council's website effectively states that the court summons will result with £55.50 being applied on top of the amount owed (for the costs of the Summons). I am making the assumption that the costs are actually added to the customer's account at this point because it is generally the approach taken by local authorities.

I am aware that in the East Northamptonshire case, the judgment went to some lengths to clarify the position with regard to when, i.e. at what stage it was permissible for a billing authority to add summons costs to a customer's account. In essence, what the judgment determined was that it was entirely lawful for the billing authority to inform the customer by stating on the summons the amount of costs it would ask for in the event it proceeded to make the application at court for a Liability Order. Implicit in this is that it is impermissible to add to the customers account at this point the costs claimed by the billing authority because there is only any legal basis to do so once the court has granted the Liability Order. The following in paragraph 28 of the judgment bears this out:

"...I have come to the clear conclusion that the summons is not an abuse of the process or otherwise invalid by reason of the fact that it includes reference to a claim for costs. The heading of the summons makes clear it seeks recovery of the Council Tax only. The complaint is therefore only as to the non payment of the Council Tax. The tax due is the Council Tax which is separately identified both on the first page and on the subsequent page. It is abundantly clear that the subject matter of the summons is therefore the recipient’s liability for the Council Tax...."

NO LEGAL BASIS TO PURSUE LIABILITY ORDER ONCE AN AMOUNT AGREED

It is also evident from information on the council's website that when a summons is issued, but before the Court hearing, it is possible to agree a payment arrangement but on the basis that the court will still be asked to grant a Liability Order which implies that the payment plan will include the costs incurred in obtaining the Liability Order (£55.50 summons and £19.50 liability order).

These costs are incurred at a point after the customer has tendered payment. Therefore, the cost attributable to this activity could not lawfully be included in the costs claimed because expenditure may only be recharged that has been incurred by the authority up to the time of the payment or tender and clearly resources called upon by engaging staff in the matter would occur after payment was tendered. Expenditure incurred by the authority after that point falls on the wrong side of line to be referable to the summons and would only be lawfully recharged (if eligible) in respect of those who had not paid or tendered to the authority the aggregate of the outstanding amount and costs before the court hearing because only those customers may be proceeded against further and incur additional costs.

To be clear, it is not just the costs in these circumstances which are artificially inflated by either front loading or being charged where there is no legal basis at all which is a point of contention. The consequences are that for all those cases against whom the council proceeds in order to secure the debt once an amount has been agreed (the payment arrangement), the action is unlawful because regulation 34 of SI 1992/613 provides that the authority shall accept the amount and the application shall not be proceeded with in these circumstances.

Paragraph 34(5) of the regulations, are as follows (with emphasis):

“(5) If, after a summons has been issued in accordance with paragraph (2) but before the application is heard, there is paid or TENDERED to the authority an amount equal to the aggregate of—

(a) the sum specified in the summons as the sum outstanding or so much of it as remains outstanding (as the case may be); and

(b) a sum of an amount equal to the costs reasonably incurred by the authority in connection with the application UP TO THE TIME OF THE payment or TENDER,

the authority shall accept the amount and the application shall not be proceeded with.”

The authority could not defend its actions on the grounds that an arrangement does not constitute payment therefore it is entitled to obtain a liability order to secure the debt because the law does not say that the amount must be paid for the application not to be proceeded with, only that the amount tendered is accepted (the aggregate of the outstanding amount and costs). By agreeing a payment plan which encompasses the outstanding amount and costs (costs which are properly referable to the enforcement process) the authority has accepted the amount and so there is no legal basis to proceed to obtain a liability order from the Magistrates' court.

Notwithstanding the lack of provision to proceed once the aggregate of the outstanding amount and costs has been agreed by the council, even if it were permissible, these costs and any other incurred would have further criteria to meet for the court to be satisfied that they were reasonably incurred.

R (Nicolson) v Tottenham Magistrates [2015] EWHC 1252 (Admin)

The Tottenham case provides in the judgment some general guidance regarding Council Tax Liability Order court costs and give clues (paragraphs 35 and 46) as to what should not be included in the costs and an approach that might be legitimate in respect of averaging the costs.

“It is clear that there must be a sufficient link between the costs in question and the process of obtaining the liability order. It would obviously be impermissible (for example) to include in the costs claimed any element referable to the costs of executing the order after it was obtained, or to the overall administration of council tax in the area concerned.” (Paragraph 35)

"In principle, therefore, provided that the right types of costs and expenses are taken into account, and provided that due consideration is given to the dangers of double-counting, or of artificial inflation of costs, it may be a legitimate approach for a local authority to calculate and aggregate the relevant costs it has incurred in the previous year, and divide that up by the previous (or anticipated) number of summonses over twelve months so as to provide an average figure which could be levied across the board in "standard" cases.." (Paragraph 46)

However, the above does not go so far as to specify what the right types of costs and expenses are, plus the 1992 Council Tax Regulations (and associated guidance) also apply so any provisions in those capable of establishing what are "relevant costs" need taking into account. Crucially, the possibility that the approach of averaging the costs is conditional upon the right types of costs and expenses being taken into account and being mindful of the dangers of artificially inflating the costs.

Government guidance from 1993 and 2013 both provide within them that "the Court may wish to be satisfied that the amount claimed by way of costs in any individual case is no more than that reasonably incurred by the authority". They do so because the court is obliged to hear individually anyone wishing to raise a defence and regulation 35(1) of the Regulations provides that a single liability order may deal with one person and one amount.

The streamlining of the process, i.e. by hearing cases of all the defendants in a bulk application who decline the invitation to defend themselves would if the law was properly applied be met with a forfeiture of costs income because only expenditure which is common to every defendant may lawfully be included in a standard sum. For example, even if expenditure attributable to engaging with customers agreeing payment arrangements was not impermissible for the reasons discussed, they would not otherwise be deemed "relevant costs" to be included in the calculation because the expenditure is not common to every defendant but also because it would be impermissible to include in the costs any element referable to the overall administration of council tax in the area concerned (para 35, Tottenham judgment).

There is also the anomaly that the customers who to the greatest degree drive the level of activity are ironically avoiding the recovery process and not incurring any costs. These are generally those customers who have negotiated their instalments being re-instated, whilst customers who settle their debt without causing additional work are left subsidising this expenditure when bizarrely none is incurred in connection with their summonses.

Expanding further on the concept of "reasonably incurred". If the costs are to be recharged lawfully to the customer it must have been reasonable for the council to have incurred them. Any expenditure recharged to the customer in respect of costs has not been reasonably incurred which is attributable to activity carried out by the council above what is necessary to secure the court order. Obtaining the order is merely a formality and it functions simply as the vehicle empowering the council to make use of a range of enforcement measures to pursue monies owed should it be necessary once it is in place, so with that in mind and that applications are made en masse, then the vast majority of costs typically claimed by local authorities are not necessary in a process which amounts to no more than seeking permission from the court.

Expenditure attributable to work carried out, which is clearly by its nature referable to the overall administration (in the area of council tax concerned) would not by virtue of it coinciding with when the complaint is in progress be sufficient to link it to the actual process of obtaining the liability order. This is separable from any that is permissible to be included in the costs claimed and would need omitting from the calculation because it would not be reasonable to expect those paying them to subsidise general administration or to be exploited as a means of funding revenues/recovery staff - and - because it is not common to every defendant.

Below is a revised list of eight obvious additional defences that would be valid if no discretion is exercised prior to requesting the issue of a summons, expenditure incurred by the council outside the process of applying for and obtaining a liability order is included in those costs and a decision to charge costs can depend on whether the council wants them to act as a penalty. They would be that;

1. the billing authority has not (does not) comply with regulation 34(1) of the Council Tax (Administration and Enforcement) Regulations 1992;

2. expenditure amounting to £55.50 was not incurred by the council in respect of instituting the complaint;

3. the costs have been inflated to subsidise customers who opt to make payment in line with the pre-arranged payment plans;

4. the costs in respect of instituting the summons include expenditure which is incurred by the council after that action;

5. decisions whether to enforce (and impose costs) which hinge on the type of debtor the council perceives the customer to be who has defaulted on payment is evidence that the enforcement process is exploited for an improper purpose, i.e. to encourage behaviour (a penalty), see Regina v Highgate Justices ex parte Petrou;

6. the costs have been inflated to subsidise expenditure incurred by the council in respect of potential applications to the court but which are not made by virtue of negotiations that have taken place to reinstate instalments;

7. the costs in general have been inflated to subsidise expenditure incurred by the council in respect of officer time monitoring arrangements and/or engaging with customers after the process of applying for and obtaining the liability order has ended; and

8. the costs in general have been inflated to fund the running of the council tax and enforcement departments and/or the overall administration of council tax in the area concerned.

Yours sincerely,

Helen Barker

Freedom of Information Mailbox, Blaby District Council

Dear Helen Barker,

Thank you for your email.

I will forward your suggestions to the relevant team and Monitoring Officer for consideration.

Kind Regards,

Andrew Hickling Legal and Information Governance Officer
0116 272 7558

VISIT OUR WEBSITE: www.blaby.gov.uk

 Please save paper and only print out what is necessary

Find out what level of service you are entitled to receive by viewing our Service Standards

To find out about how we use your personal information, please review our privacy notice

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