Anna Jamroz v Mohammed Javid Tariq Ali

Decision date: 11 August 2025

Neutral citation: [2025] UKUT 265 (LC)

Overall AI summary confidence: high

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Short overview

This short overview is intended to summarise the case, issues and outcome so far as they are supported by the judgment.

AI confidence in this short overview: high

This appeal concerned whether the First-tier Tribunal (FTT) had jurisdiction to grant a rent repayment order (RRO) because the tenant’s RRO application was emailed at 11:15pm on the last day of the 12‑month limitation period. The Upper Tribunal held the application was made in time because an application is made on the date it is sent to the FTT by email, including when sent outside office hours, and that the 12‑month period includes the whole day the application is made. The UT allowed the appeal, affirmed the FTT’s jurisdiction, and confirmed the FTT’s alternative findings that the landlord committed the offence and must repay £2,790 plus £320 fees.

Ratio decidendi

This summary is intended to identify the ratio decidendi, meaning the legal reasons for deciding and the binding part of the decision.

AI confidence in this ratio decidendi summary: high

The binding ratio from the notes is that an application to the FTT is "made" on the date it is sent to the FTT by email even if sent outside office hours, and that the statutory 12‑month period "ending with the day on which the application is made" includes the whole of that day.

Obiter dicta

This summary is intended to identify obiter dicta, meaning observations made by the way that were not necessary to deciding the case and are not binding.

AI confidence in this obiter dicta summary: medium

The notes record that the UT did not decide substantive challenges to the prior Tribunal decision on timing and left those arguments for another day; the decision also notes the practical utility of the FTT making alternative findings when jurisdiction is disputed. These observations appear as commentary rather than binding reasoning.