Subject: UK Appeal update
From: Alki David <[email-masked]>
To: James Bohm <[email-masked]>, Ceci Preciado <[email-masked]>, Cynthia Lopez <[email-masked]>, Antonia Leseth <[email-masked]>
Date: Wed, 24 Dec 2025 03:17:10 -0800

For your records = UK appeal Court verification and submitted Skeleton IN
THE COURT OF APPEAL (CIVIL DIVISION)

*Appeal No:* CA-2025-002562
*High Court Ref:* KB-2025-001991
Between

*ALKIVIADES DAVID*
*Appellant*

-and-

*MAHIM KAHN*
*Respondent*
------------------------------
SKELETON ARGUMENT

*ON BEHALF OF THE APPELLANT*
------------------------------
A. INTRODUCTION

   1.

   This is the Appellant’s Skeleton Argument in support of:
   (a) permission to appeal (if required); and
   (b) the substantive appeal.
   2.

   The appeal concerns *serious procedural unfairness and material
   irregularity* in the proceedings below, such that the resulting order
   cannot safely stand.
   3.

   The appeal is directed to *threshold errors of law and procedure*. It
   does *not* invite this Court to determine disputed factual issues at
   this stage.

Disability & Reasonable Adjustments (Procedural Note)

   4.

   The Appellant appears as a litigant in person and is a disabled person
   within the meaning of the *Equality Act 2010*. He respectfully invites
   the Court to note that reasonable procedural adjustments may be required to
   ensure effective participation and equality of arms, consistent with the
   Equality Act 2010 and *Article 6 ECHR*. No prejudice is caused to any
   party by such adjustments.

------------------------------
B. ISSUES ON THE APPEAL

   5.

   The appeal raises the following issues:

*Issue 1 — Fair Hearing*
Whether the Appellant was denied a fair hearing contrary to Article 6 ECHR
and common law principles of natural justice.

*Issue 2 — Procedural Irregularity*
Whether the proceedings below were vitiated by material procedural
irregularity rendering the outcome unjust.

*Issue 3 — Failure to Engage / Error of Law*
Whether the court below failed to engage with the Appellant’s pleaded case
and evidence, amounting to an error of law.

*Issue 4 — Equality of Arms*
Whether the cumulative conduct of the proceedings resulted in inequality of
arms inconsistent with Article 6 ECHR.
------------------------------
C. BACKGROUND (SUMMARY)

   6.

   The Appellant was a party to proceedings in the King’s Bench Division
   which resulted in orders adverse to him, including a substantial costs
   order.
   7.

   Throughout the proceedings, the Appellant sought to place before the
   court substantial documentary material bearing on liability, procedure, and
   costs.
   8.

   The Appellant contends that:
   (a) material evidence was not properly considered;
   (b) procedural steps were taken which foreclosed effective
   participation; and
   (c) the outcome was reached on an incomplete evidential footing.

------------------------------
D. ISSUE 1 — DENIAL OF A FAIR HEARING

   9.

   Article 6 ECHR guarantees a right to a fair hearing, including:
   (a) equality of arms;
   (b) a real opportunity to present one’s case; and
   (c) judicial engagement with that case.
   10.

   A hearing is not fair where a party is:
   (a) unable effectively to present submissions;
   (b) prevented from deploying material evidence; or
   (c) subjected to procedural foreclosure rather than adjudication.
   11.

   The Appellant submits that the *cumulative effect* of the procedural
   steps taken below amounted to a denial of a fair hearing.
   12.

   Where Article 6 is breached, the resulting order is unsafe and must be
   set aside.

------------------------------
E. ISSUE 2 — MATERIAL PROCEDURAL IRREGULARITY

   13.

   The Court of Appeal may intervene where a serious procedural
   irregularity has occurred and has rendered the decision unjust.
   14.

   The irregularities include, in summary:
   (a) failure to consider or engage with relevant evidence;
   (b) procedural directions operating punitively rather than
   proportionately;
   (c) refusal to permit effective participation by a litigant in person.
   15.

   These were not discretionary case-management choices but *structural
   defects* in the conduct of the proceedings.
   16.

   The correct question is whether the irregularity *might* have affected
   the outcome. The Appellant submits that it plainly did.

------------------------------
F. ISSUE 3 — FAILURE TO ENGAGE WITH THE CASE

   17.

   The court below failed to:
   (a) identify and address the real issues raised by the Appellant;
   (b) engage with the substance of his evidence and submissions;
   (c) provide reasons demonstrating proper consideration of his case.
   18.

   A failure to engage with a party’s core case constitutes an error of law.
   19.

   Appellate restraint does not apply where a first-instance decision is
   reached without such engagement.

------------------------------
G. ISSUE 4 — EQUALITY OF ARMS

   20.

   The Appellant submits that the manner in which the proceedings were
   conducted resulted in a material inequality of arms.
   21.

   The combination of procedural restrictions, evidential exclusion, and
   the Appellant’s status as a litigant in person deprived him of a fair
   opportunity to present his case.
   22.

   This independently justifies appellate intervention.

------------------------------
H. EVIDENCE

   23.

   The Appellant has lodged extensive documentary material, including
   correspondence and procedural records, which directly bears on:
   (a) fairness;
   (b) notice; and
   (c) the integrity of the proceedings.
   24.

   To the extent such material was not fully considered below, this was due
   to the very procedural failures complained of.
   25.

   The Appellant invites the Court to consider such material insofar as
   necessary to assess fairness and procedural integrity.

------------------------------
I. RELIEF SOUGHT

   26.

   The Appellant respectfully seeks:
   (1) Permission to appeal (if required);
   (2) That the appeal be allowed;
   (3) That the order(s) below be set aside;
   (4) That the matter be remitted for rehearing before a differently
   constituted court, with directions to ensure procedural fairness and
   equality of arms;
   or such other relief as the Court considers just.

------------------------------
J. CONCLUSION

   27.

   This appeal is concerned with *whether justice was done*, not with the
   ultimate merits of the underlying dispute.
   28.

   The Appellant submits that serious procedural unfairness occurred and
   that appellate intervention is required to restore confidence in the
   process.

Hi allAppeals court stamp attached I filed this skeleton in London after
reciving confirmation athat the appeal was live STATEMENT OF TRUTH

I believe that the facts stated in this Skeleton Argument are true.

Signed electronically:
/s/ *Alkiviades David*
Appellant (Litigant in Person)
*Date:* 23 December 2025