1 Bundle 04 April 2024 (6517080.1)

Case No: BR- 2020- 000102
IN THE HIGH COURT OF JUSTICE BUSINESS AND

PROPERTY COURTS OF ENGLAND AND WALES
INSOLVENCY AND COMPANIES LIST
IN THE MATTER OF MOHAMMAD KAMAL AHMED IN BANKRUPTCY
AND IN THE MATTER OF THE INSOLVENCY ACT 1986
B E T W E E N:-
CHRISTOPHER WILLIAM PARKMAN

(TRUSTEE IN BANKRUPTCY OF MOHAMMAD KAMAL AHMED)
Applicant
and
(1) MOHAMMAD KAMAL AHMED

First Respondent
(2) SUFIA BEUM

Second Respondent
INDEX TO BUNDLE FOR HEARING ON 4 APRIL 2024 AT 10:30AM
Index
TAB DOCUMENT PAGES
1 Application Notice dated 23 February 2024 3-5
2 Draft Order 6-8
3 Witness Statement of Christopher William Parkman dated 23 February 2024 9 - 13
4 Exhibit CWP1 dated 23 February 2024 14 - 61
5 Certificate of service for Sufia Beum dated 14 March 2024 62 - 63
6 Certificate of service for Mohammad Kamal Ahmed dated 14 March 2024 64 - 65
1
7 Letter to Court filing the Certificates of Service dated 14 March 2024 66
8 Proof of delivery 67
2
Form IAA
Rule 1.35
Insolvency Act Application Notice
See Form IAA-N for

guidance notes on
how to complete BR-2O2O-OOO1O2
this Form IAA Hearing Date: 04 Apr 2024 10:30
Insert case or as soon
number if the case No: BR-2020-0001W1ereafter to be
court has heard in person at
assigned one
the Rolls Building
Delete/ [a] IN THE HIGH COURT OF JUSTICE
complete BUSINESS AND PROPERTY COURTS OF ENGLAND AND
as WALES
necessary: INSOLVENCY AND COMPANIES LIST (ChD)
IN THE MATTER OF MOHAMMAD KAMAL AHMED IN
BANKRUPTCY
Insert name of BETWEEN

Debtor/bankrupt
or company
Insert name(s) CHRISTOPHER WILLIAM PARKMAN (TRUSTEE IN APPLICANT
of applicant(s) BANKRUPTCY OF MOHAMMAD KAMAL AHMED)
AND
Insert name(s) (1) MOHAMMAD KAMAL AHMED RESPONDENTS
of respondent( s) (2) SUFIA BEUM
Delete/complete This Application is made pursuant to section 283A (6) of the Insolvency Act 1986
as applicable
Insert required The Applicant is Christopher William Parkman (the Trustee in Bankruptcy of
details (name, Mohammad Kamal Ahmed) of Corporate Recovery Specialists trading as Purnells
address, etc) of Insolvency Practitioners of 5a Kemick Industrial Estate, Penryn, Nr Falmouth,
applicant(s) Cornwall, TR10 9EP.
Insert required The First Respondent is Mohammad Kamal Ahmed of 214 Plashet Grove, London,
details (name, E6 1 DA and the Second Respondent is Sufia Beum of 214 Plashet Grove,
address, etc) of London, E6 1 DA
respondent(s)
Identify level of This Application is made to the Insolvency and Companies Court Judge in the
judge and court High Court of Justice
or hearing centre
(as per heading)
Delete as Is this application within existing insolvency proceedings? YES
applicable and if The court reference number for the proceedings to which this application relates is
YES, insert the BR-2020-000102.
number
assigned by the
court
IAA - Insolvency Act Application Notice (04.17)
3
4
5
Case No: BR- 2020- 000102

BEFORE:
B E T W E E N:-

Applicant
and
(1) MOHAMMED KAMAL AHMED First Respondent
(2) SUFIA BEUM

Second Respondent
DRAFT ORDER
UPON the Applicant’s application dated 23 February 2024
AND UPON reading the Witness Statement of Christopher William Parkman dated 23 February 2024
AND UPON hearing Counsel for the Applicant and [Counsel for the Respondents]
IT IS ORDERED THAT:
1. The three-year period as set out in section 283(A)(2) of the Insolvency Act 1986 be extended by
two years to 24 May 2026 pursuant to section 283(A)(6) of the Insolvency Act 1986 in relation
to the following properties:
1.1 197 Plashet Grove, London E6 1BX

1.2 25 Rothsay Road, London, E7 8LY
6
1.3 48 Shaftsbury Road, London, E7 8PD
1.4 17 Bristol Road, London, E7 8HG
1.5 214 Plashet Grove, London, E6 1DA
1.6 2 Keppel Road, London, E6 2BD
2. Costs of the Application
Dated this day of February 2024
Service of this Order
This Order shall be served by the Applicant, as the serving party, on the Respondents. The Court has
provided a sealed copy of this Order to the serving party’s solicitors, Isadore Goldman, Suite 316, 3rd
Floor, 70 Gracechurch Street, London, EC3V 0HR.
7
Case No: BR-2020-
000102
IN THE HIGH COURT OF JUSTICE

BUSINESS AND PROPERTY COURTS
OF ENGLAND AND WALES
IN THE MATTER OF MOHAMMAD KAMAL
AHMED IN BANKRUPTCY
AND IN THE MATTER OF THE
INSOLVENCY ACT 1986
BEFORE [NAME OF REGISTRAR OR

JUDGE]
B E T W E E N:-

(TRUSTEE IN BANKRUPTCY OF
MOHAMMAD KAMAL AHMED)
Applicant
and

First Respondent
(2) SUFIA BEUM
Second Respondent
-------------------------------------
DRAFT ORDER
-------------------------------------
Isadore Goldman
Suite 316, 3rd Floor
70 Gracechurch Street, London
EC3V 0HR
Tel: 020 7353 1000
Ref: MK/PUR1114
Solicitors for the Applicant
8
9
10
11
12
13
Case No: BR-2020-000102

B E T W E E N:-

Applicant
and

First Respondent
(2) SUFIA BEUM
Second Respondent
EXHIBIT CWP1
This is Exhibit CWP1 referred to in the Witness Statement of Christopher William Parkman dated 23
February 2024.
14
- -
TRUST DEED
o/
THIS DECLARATION OF TRUST is made th� day of 2008
between:
(I) Mohammad Kamal Ahmed ( hereinafter called "Kamal" ) of 261A High Road,
South Benfleet, Essex, SS7 SHA and
(2) Dabir Nozrul Islam Ahmed ( hereinafter called "Dabir") of 261 A High Road, South
Benfleet, Essex, SS7 SHA and
• (3) Hazrat Fatema Bibi ( hereinafter called "Hazrat" ) of 214 Plashet Grove, London,
E61DA and
(4) Kabir Ahmed ( hereinafter called "Kabir") of 214 Plashet Grove, London, E6 1D A
and
(5 ) Begum Sufia Ahmed ( hereinafter called '·Sufia.. ) of 214 Plashet Grove, London,
E6 IDA and
(6) Afia Begum Ahmed ( hereinafter called "Afia") of 6 Tudor Road, London, E9 ?SN
NOW THJS DEED WlTNESSETH as follows:
•
1. DEFINITIONS
1.1 "Property" means those properties which are set out in Schedule One herewith and
any subsequent properties purchased or held by Kamal and Dabir by a way of share
, leasehold, freehold or any other fonn specified or otherwise in this agreement until
such time this agreement is ratified/ amended or superseded by a subsequent
agreement; agreed upon by all parties concerned.
1.2 By "Beneficiary" means Kamal, Kabir, Dabir, Sufia, Afia and Hazrat as an individual
as a director of a company or as any trading name now and in future, any future name,
15
name change or any other form he/she may change into time to time including but
not limited to any asset held under it been taken under a limited Liability/ private/
individual sole ownership or partnership._
1. 3 "Mortgage"means the mortgages and any charging orders which are secured over the
Property from time to time
1.4 "Net Proceeds of Sale" means the sale price less any monies outstanding on any legal
and or interim charges registered against the Property, legal costs and disbursements
relating to the sale and any estate agents' commission
1 .5 "Shares" means the shares in which the Property is held in for each of the parties
in accordance with Clause 3.1 of this Deed and "Share" shall have the
corresponding meaning
1.6 "Shareholding" means the number of shares in which the property is held when the
property is owned or operated ,vithin a limited company.
l .7 "Value" means the value ofthe Property such value to be ascertained by an independent
valuer �structed by both parties jointly (or the surviving party and the personal
representative of the deceased party's estate jointly if applicable) or if no agreement
can be reached to be appointed by the President of the Royal Institute of Chartered
Surveyors from time to time at the application of either party at the joint cost of the
parties provided that both parties are still alive and otherwise at the cost of the surviving
party such value to be valid for a period of 6 calendar months and "Valuation" shall
have the corresponding meaning.
1.8 "Mortgage Value" means the value of the Mortgage Outstanding on the property to
be ascertained by a Redemption Statement from the Lender dated within 28 days.
1.9 '•Director" means the appointed director of a company or the individual appointed to
be the director a company under which the property is held.
16
2. BACKGROUND
2.1 This declaration affirms that the parties purchased the Property jointly over a period
of time and the Property is held by the parties hereto for an estate in fee simple.
2.2 The parties have agreed that Dabir & Kamal will be responsible for all outgoings
of the Property including the Mortgage re-payments.
?
-·-'... The parties hereto have agreed that from the date hereof the Property has been held
by them and will continue to be held by them on trust as set out in Clause 3.1 to this
Deed.
3. OPERATIVE PART
3.1 The parties hereto declare that as from the date hereof the Property has been held and
will continue to be held by them as beneficial tenants in common upon trust for
themselves in the following shares:
3.1. I As to the % shares absolutely described in SCHEDULE ONE for Kamal,
Kabir, Dabir, Sufia. Afia and Hazrat.
.,... __? Pending the sale of the Property the parties hereto agree and covenant with each other
that:
3.2.1 Subject to Clause 3.3.1 of this Deed all parties shall be permitted to occupy
the Property, if they so wish, as their residence for as long as they desire whilst
they have a Share or they may let out the Property as they may desire subject
to compliance with all statutory requirements and by laws which may be in
force from time to time;
3.2.2 the Property shall be insured in the full reinstatement value thereof and all
parties shall be jointly responsible for paying all premiums payable in respect
17
.,
of such insurance
3.2.3 It is agreed that any interim charging orders or any other charge orders that
may time to time become secure� against the Property shall be paid from the
share of the respective party/parties and other parties shall not be liable to
contribute towards those payments
3.2.4 Kamal & Dabir will jointly be responsible for all Mortgage re-payments as the
mortgages are obtained under these 2 names only.
3.3 The parties hereto further agree that:
3.3. l should any party or all parties wish to sell the Property or realise their Share;
3.3.1.1 other party within thjs agreement shall be given the first option to purchase
the Property by way of payment to the other party wishing to sell off her/his
share of the Value provided that both parties agree and covenant that
they will do all required to ensure that the Valuation is obtained as soon as
reasonably practicable and provided that each party shall exercise such
option within three calendar months from the date of the Valuation and
shall complete on such purchase within six calendar months from the date of
the Valuation;
3.3 .1.2 ifsuch option is not exercised by one pa1ty within the time period specified, other
party shall be given the option to purchase the Property by way of payment to
party wishing to sell of his/her % Share of the Value on the same provisos
as set out in sub clause 3.3.1.1 hereof;
3.3.1.3 ifsuch option is not exercised by either party within the periods specified above
the Property shall be sold as soon as practicable on the open market and all
parties undertake to take all reasonable steps required to sell the Property as
soon as practicable
18
On the death of one party the sUf\·iYing party/ parties shall be given the option to
purchase the Property by way of payment to the Executors or Personal
Representatives of the deceased pany·s estate of that deceased party's Share of the
Value provided that such party shall exercise such option within three calendar months
from the date of the Valuation and shall complete on such purchase within six calendar
months from the date of the Valuation or within twelve calendar months from the Grant
of Probate or Grant of Representation, whichever is the later, unless a longer period is
agreed by the said Executors or Personal Representatives
4. DURATION OF THIS AGREEMENT
4. l This agreement is valid until such time this agreement is ratified/ amended or
superseded by a subsequent agreement agreed ; upon by all parties concerned.
19
SCHEDULE ONE
Address Title Dabir's Kamal's Hazrat's Kabir's Sufia's Afia's

Number Beneficial Beneficial Beneficial Beneficial Beneficial Beneficial
Interest Interest Interest Interest Interest Interest
Absolute Absolute Absolute Absolute Absolute Absolute
4 1 Rothsay NGL183516 20% 0% 20% 20% 20% 20%
Road,
London, E7
SLY
112 Strone NGLl 12612 95% 5% 0% 0% 0% 0%
Road,
London, E7
SES
2 Keppel EGL526927 5% 95% 0% 0% 0% 0%
Road,
London, E6
2BO
214 Plashet EGL349540 0% 0% 0% 0% 50% 50%
Grove,
London, E6
I DA
17 Bristol EGL148320 5% 95% 0% 0% 0% 0%
Road,
London, E7
8HG
48 EGL186447 0% 20% 20% 20% 20% 20%
Shaftesbury
Road,
London, E7
8PD I
25 Rothsay EGL79134 0% 0% 0% 0% 50% 50%

Road,
London,E7
8LY
197 Plashet EGL460707 0% 0% 100% 0% 0% 0%
Grove,
London,E6
l BX
43 Rothsay EGL35344 0% 0% 0% 100% 0% 0%
Road,
London,E7
8LY
307 EGL306414 95% 5% 0% 0% 0% 0%
Katherine
Road,
London, E7
8PJ
20
IN WITNESS whereof the parties have duly executed these presents as a deed the day and
year first above written:
SIGNED as a DEED by the said
Afia Begum Ahmed
Mr Mohammad Kamal Ahmed
Dabir Nozrul Islam Ahmed
Hazrat Fatema Bibi
- Kabir Ahmed �
Begum Sufia Ahmed
in the presence of:- �

Signature:
Name: 00•-it--.J Pk:t�O dJ
Address:
i2L MAJ.Jo� 1eor-i10 . J_o,�t-1 1 N l 1 O::f't€-
Occupation: �N �INC- C �
21
CALUATION ASSUMING
l. NO TRUST DEED IN PLACE AND MOHAMMED BENEFICIAL INTEREST IS 50 %
2. Elias debt is same as Petition debt of £391,629.99
3. MKA IS 100% RESPOSIOLE FOR Bank ofScotland Debt
- . -
Amount left
fo l er
sale and
NO I �:;;� �� Monthly disposable
Property Address Mortgage Salilnce Current Valuation Monthly Mortgage Account
I Title Number I Dates of Cha,ge Orders I I I mortga1e
I IAgent fees I I Mortgage company
rental Income payments Income number
payment Beneficial I I
EGL3S344 6.7.15 £251,158.28 £541,000 £289,841.72
43 Rothsay Road, London £7
SLY £1,450.00 £280.00 £916.75 £253.25 NRAM 631525500
EGL79l34 6.7.15 £233,655.23 £400,000 £166,344.77

25 Rothsay Road, London E7
SLY £83,172.39 £950.00 £190.00 £410.04 £349.96 BIRMINGHAM MIDSHIRES 20013010735
NGLl835l6 6.6.IS and 09.06.2021 E244,604.78 £487,000 £242,39S.22

BLY £1,600.00 £310.00 £431.67 £858.33 BIRMINGHAM MIDSHIRES 20013024515
EGLl86447 6.7.IS £214,455.40 £504,000 £289,544.60

48 Shaftsbury Road, London £7
4
SPD £1,650.00 £360.00 £379.96 £9I0.04 TOPA2 RE ROSOLITE 520450106
EGL460707 6.7.15 £197,258.17 £473,000 E275,741.83 098497449500

197 Plashet Grove, London £6
IBX £0.00 £0.00 £903.02 ,£903.02 Alliance & Leicester
6.7.15, 9.7.15, 9.6.16,
EGLl48320 £222,082.97 £486,000 E263,917.03
17 Bristol Road, London £7
6 I 8HG 18.10.16 £1,550.00 £310.00 £390.52 £849.48 KENSINGTON 667948302
EGL349540 24.11.2014 £310,398.98 £393,000 £82,601.02

214 Plashet Grove, London £6
IDA £0.00 £0.00 £1,091.23 .£1,091.23 HELIDOR 260841705
6.7.15, 9.7.15, 9.6.16,
EGL526927 £109,168.94 £234,000 £124,831.06
Flat 2, 2 Keppel Road, London
E6 2BD 18.10.16 £62,415.53 £1,000.00 £200.00 E4l3.02 £386.98 TOPA2 RE SIBERITE 668624906
TOTAL £1,782,782.75 £3,518,000.00 £1,735,217.25 £8,200.00 El,650.00 £4,936,21 El,613.79
divided by 2
£806,90
TOTAL AVAILABLE FOR CREDITORS
- ·· - �
81\LANCE LEFT
AFTER for Petitioner
NO I Property Address I Tld• Numbor I Dates of Charge Orders I Mortgage Balance I Current Valuation I MORTGAGE based on
Monthly
A ent fees
rental income 8
I I Mortgage
payments
I Monthly disposable
Income Mortgage company
Account
Beneficial I I number
REDEMPTION I
EGL35344 6.7.15 £251,158.28 £541,000 £289,841.72

SLY £1,450.00 £280.00 £916.75 £253.25 NRAM 631525500
EGL79l34 6.7.15 £233,655.23 £400,000 £166,344.77

2S Rothsay Road, London E7
SLY £950.00 £190.00 £410.04 £349.96 BIRMINGHAM MIDSHIRES 200130I0735
NGll83516 6.6.15 and 09.06.2021 £244,604.78 E487,000 £242,395.22

SLY £1,600.00 £310.00 £431.67 £858.33 BIRMINGHAM MIDSHIRES 20013024515
EGll86447 6.7.15 E2l4,455.40 £504,000 E289,544.60 £1,650.00 £360.00 £379.96

8PD £9I0.04 TOPA2 RE ROSOLITE 520450106
4 1 48 Shaftsbury Road, London E7
EGL460707 6.7.15 £197,258.17 £473,000 £275,741.83 i 098497449500

197 Plashet Grove, London E6
lBX £0.00 £0.00 £903.02 -£903.02 All ance & Leicester
6.7.15, 9.7.15, 9.6.16,
6 EGLl48320 £222,082.97 £486,000 £263,917.03
17 Bristol Road, London E7
I 8HG 18.10.16 £1,550.00 £310.00 £390.52 £849.48 KENSINGTON 667948302
EGL349540 24.11.2014 £310,398.98 £393,000 £82,601.02

!DA £0.00 £0.00 £1,091.23 ·£1,091.23 HELIOOR 260841705
6.7.15, 9.7.15, 9.6.16,
EGL526927 £109,168.94 £234,000 £124,831.06
E6 28D 18.10.16 E62,415.53 £1,000.00 £200.00 £413.02 £386.98 TOPA2 RE SIBERITE 668624906
POTENTIAL COST
Estate A ent Fee I 5% £43 380.43

10% OF.OUCTION IN FORCED SALE (86 760.86
Le at Cost 5% £43 380.4]
CGT I 30'¼ (260 281.59
Others I £15 000.00
!TOTAL COST £4<8 00011

BALANCE REMAINING £418 804.311
22
SUMMARY OF CREDITORS
NO NAME GRANO TOTAL PERCENTAGE OF OEBT OISTRIBUTION OF ASSET

1 DABIR NOZRUL ISLAM AHMED £ 1 875667. 03 62.08 £259 985.44
2 BEGUM SUFIA AHMED (280 248.00 9.28 [38 845.2 1
4 HAZRAT HUSSAIN £195 455.00 6.47 f.27 092.04
5 DR ANISAH TARIO f.340 000.00 11 .25 £117 127.44
6 MUHAMMAD ABDUL KADIR £66 957.53 2.22 £9 280.99
7 Jalal Uddin £70 000.00 2.32 (9 702.71
8 HMRC £8 751. 13 0.29 fl 213.00
9 EUAS DEBT £0.00 0.00 £0.00
10 BANK OF SCOTLAND (184.376.79 6.10 £25 556.49 Hussain is 50 % Liable for this debt and credit should be �iven
!TOTAL £3 021 455.48! 100.ool £418 804.31!
23
Amount left
fo ' er
NO after sale and
I Property Address Dates of Charge Orders Mortgage Balance Current Valuation I �::!� :� Monthly
g Monthly disposable Account
mortgage
I I I Mortgage I Mortgage company
I Title Number I I I rental Income A ent fees payments rncome number
payment Beneficial I I
EGL35344 6.7.15 £251,158.28 £541,000 £289,841.72
SLY £1,450.00 £280.00 £916.75 £253.25 NRAM 631525500
£GL79134 6.7.15 £233,655.23 £400,000

SLY £166,344.77 £0.00 £950.00 £190.00 £410.04 £349.96 BIRMINGHAM MIOSHIRES 2001l01073S
3 NGL183516 6.6.15 and 09.06.2021 £244,604.78 £487,000

41 RothsayRoad, London E7
8LY £242,395.22 £0.00 £1,600.00 £310.00 £431.67 £858.33 BIRMINGHAM MIDSHIRES 20013024515
£Gll86447 6.7.15 £214,455.40 £504,000 £289,544.60

48 Shaftsbury Road, London E7
8PD £57,908.92 £1,650.00 £360.00 £379.96 £910.04 TOPAZ RE ROSOLITE 520450106
EGL460707 6.7.15 £197,258.17 £473,000 £275,741.83

!OX £0.00 £0.00 £0.00 £903.02 ·£903.02 Alliance & Leicester 0984974495001
6.7.15, 9.7.15, 9.6.16,
6 £Gll48320 £222,082.97 £486,000
I 8HG £263,917.03 £1,550. 00 £310.00 £390.S2 £849.48 KENSINGTON
18.10.16 667948302
EGL349S40 24.11.2014 £310,398.98 £393,000 £82,601.02

IDA £0.00 £0.00 £0.00 £1,091.23 -£1,091.23 HELIDOR 26084170S
6.7.IS, 9.7.15, 9.6.16,
EGLS26927 £109,168.94 £234,000
E6 20D £124,831.06 £1,000.00 £200.00 £413.02 £386.98 TOPAZ RE SIBERITE
18.10.16 668624906
TOTAL £1,782,782,7S £3,S18,000.00 £1,735,217.2S £8,200.00 £1,6S0.OO £4,936.21 £1,613.79
£806.90
TOTAL AVAILABLE FOR CREDITORS
fo�::�:':�er
Amount left
NO
I Monthly
Property Address Dates of Charge Orders Mortgage Balance after sale and Monthly disposable Account
Current Valuation I I I Mortgage company
I Title Number I I I mortgage rental Income Asent fees payments Income number
I Mortgage I
payment Beneficlal I I
£Gll86447 6.7.IS £214,455.40 £504,000 £289,S44.60
148 Shaftsbury Road, London E7
8PO £1,6SO.OO £360.00 £379.96 £910.04 TOPAZ RE ROSOLITE 5204S0106
6.7.15, 9.7.IS, 9.6.16,
EGL148320 £222,082.97 £486,000 £263,917.03
8HG 18.10.16 £1,550.00 £310.00 £390.52 £849.48 KENSINGTON 667948302
6.7.15, 9.7.15, 9.6.16,
3 EGLS26927 £109,168.94 £234,000 £124,831.06
I E6 2BD 18.10.16 £1,000.00 £200.00 £413.02 £386.98 TOPAZ RE SIBERITE 668624906
TOTAL £S45,707,31 £1,224,000.00 £678,292.69 £4,200.00 £870.00 £1,183.50 £2,146.50
POTENTIAL COST
Estate Auent Fee 5% £21 360.98

£42 721.96
10 % DEDUCTION IN FORCED SALE
I
le11al Cost 2% £8 544.39
CGT 28% {119 621.49
01hers £5 000.00
I
I
!TOTAL COST D97,248.82!
IBALANCE REMAINI.NG £229 970.78!
SUMMARY OF CREDITORS
TOTAL ASSET AVAILABLE £229,970.78
NO NAME GRANO TOTAL PERCENTAGE OF DEBT DISTRIBUTION OF ASSET

DABIR NOZRUL !SLAM AHMED £1 875 667.03 62.08 £142 761. 86
2 OEGUM SUFIA AftMEO £280 248.00 9.28 £21 330.40
HAZRAT HUSSAIN 6.47 ( 1 4 876.59
5 OR ANISAII TARIQ £340 000.00 ll.25
()95 455.00
£25 878.28
MUHAMMAD ABDUL KADIR £66 957.53 2.22 £5 096.3 1
7 Jalal Uddin £70 000.00 2.32 £5 327.88
8 HMRC £8 751.13 0.29 £666.07
9 ELIAS DEBT £0.00 - - 0.00 1
£0.00!Elias is fU'"ii vecute dlJ'v'.:wav of charging orders,-----��-..
24
0
z
s
�
0
"z
0
"'<
...
::!.
...
0
25
BKT58771 37 PRENAR
IN THE HIGH COURT OF JUSTICE • 1 02 of 2020
MOHAMMED KAMAL AHMED

IN BANKRUPTCY
•• Statement made in pursuance of a requirement im posed under section 291 of the

lnso!vericy _Act 1 986 before Megan Brooker
by MOHAMMED KAMAL AHMED . . •.
of 214 PLASHET GROVE, LONDON, E6 1 DA
on 1 1 JUNE 2021
by telephone, and amended by email 1 6 J u ne 2021 ,·
Section 5 of thePerjury Act 1911
If any per�;on knowingly and wilfully makes (otherwise than· on oath) a statement false in a
material particular, and the statement is made:
. .
a) in a statutory declaration, or
b) in an abstract, account, balance sheet, book, certificate, declaration, entry, estimate,

inventory, notice, report, return or other document which he is authorised or required to make, .
. attest, or verify, by any public general Act of Parliament for the time being in force,
. .
c) in any oral declaration or oral answer.which he is required to make by, under or in
pursuance of any public general Act of Parliament for the time being in force,
he shall be guilty of a misdemean_our and shall be liable on conviction thereof on indictment to

imprisonment for any term not exceeding two years, or to a fine or to both such imprisonment
and fine.
. .
This statement has -been compiled from my responses to q uestions putto me by Megan
Bro�e�
The attached statement, consistin g of 4 pages has been read by me and I confirm that it is true
to the best of my knowledge , information and be_lief.
I confirm that I made this statement after Section 5 of the Perj ury Act 1 91 1 was rea� by me and
that I understood its meaning_.
I have no objection to this narrative stateme.nt and my Preliminary Information Questionnaire

being shown to any Insolvency Practitioner who may be appointed as Trustee in bankruptcy.
1?
Date: ______ u_
J_n e__
2_2 1______
0_
26
RE: Mohammed Kamal Ahmed Narrative page -"1'---_ of 4
My full a nd true name is Mohammed Kamal Ahmed arid my date of birth is 28/1 2/1975. and I
currently reside at 1.97 Plashet Grove, London, E6 1 DX. I am currently employed as a consultant.
I have not been known by any other name.
I was made bankrupt by Elias Hussain fo r the sum £391 ,629.39, a debt that I dispute.
In. 2007, Elias Hussain, who was a dose family friend, came to me with a proposition to buy the
property 2 Keppel Road (that comprised at the time as 2 and 2A Keppel Road; 2 Keppel Road
was arranged . as Flat 1 and Flat 2 and 2A Keppel Road as, commercial Unit at the front and a
warehouse at the rear) with the purpose of developing it, seUing it and splitting the profit. However,
on the day of completion oElias told me that he didn't have his 5 0% share of the purchase costs
and I ended up paying f r the wh.ole property by borrowing Elias' share from my brother Dabir
Ahmed. (Ultimately, I also paid for all except £2,985 of the legal costs because Elias did not have
the funds at the time of completion}. I borrowed a total of £425k for the property, but I stuck to the
deal with Elias and the property was ·registered under both our names. The development ended
up creating a total of 5 flats and a commercial unit.
The property was re:-mortgag·e d in 2008 with Bank of Scotland for the sum of £385, 000 and, as
the property was in joint nanies, the solicitor split the borrowed funds between myself and Elias
Hussain arid we both received £1 25k. The deal was he would repay me the £125k that he had
received but he only paid me £25k in the end and gave various reasons why he couldn't pay the
rest. He never did repay the other £100k.
In 2009, I �iscovered that the family business owed £85k to a builder's merchants. Elias had been
employed by the family business and I confronted him about it. He stated that he had obtained
materials frorri the Builder's M.erchant� on our business account to develop his own house, 240
Monega Road, London, E12 6TS. He had also run up significant debt with other local suppliers
such as CSS DIY; London Plumbing and others: trading on our good family name. I confronted
him again when I discovered a paymentfrom the company account of £13k to Elias' wife and that
he had not deposited my tenant's deposit monies into the deposit scheme. He had not returned
these fun ds to my tenants when they left the respective tenancies and I estimate (and have
evide.nce of) that he had kept £53k of tenant's money. I later came to know he had purchased
. 222 Nightingale Road, London, N9 BPS with the money stolen from tenant's deposits.
I spoke to him and advised that he had put us in an untenable position. Elias initially disc;1ppeared
for a bit and later I learnt he went to Morocco without informing me. When he returned some 3-4
weeks later I managed to organise a meeting and during the meeting Elias became very agitated
and angry, he threw the table across the room and left the meeting. Later, in Jan 2 0 1 0 , we had
another meeting in the presence of other family elders, together with few friends we both knew.
We agreed that I would pay him £ 1 30 , 000 for liis entire beneficial st,are of.both 2 and 2A Keppel
Road. It was agreed Elias would hand over his beneficial interest via his solicitors in return for
£1 30, 000 and he would keep the £1 00 , 000 that he had received as a part of the re-mortgage with ·
Bank of Scotland. · 1t was agreed he would meet his solicitor arid provide him with the necessary
instructions for the property to be handed over to my brother and I. In the meantime, Elias called
me and said he had an emerger,cy come up, he need.ed to travel to Bangladesh for an emergency
and needed some urgent cash. He had told me his father '#.8S dying back in Bangladesh and he •
j ust wanted to see him for one last time. I just lost my own father at the time and I was mentally ·
very vulnerable. I felt sorry for him and paid • . £7,800 both in bank transfors and cash as part
of the £ 1 30 ,000 aQree ent. Elias then d" ppeared for few weeks and had r instructed the
�
• interviewee: __,,.c.,.g.��";;..::;i:�;;,.:;;..__;� Examiner:
;4f/h� ✓
.
1_
Date: .______7 J_ne
u_ 2_0_
_.;.. 2 1_____
27
RE: Mohammed Kamal Ahmed Narrative pa ge 2 of '4
solicitor, as agreed, to hand over the property upon his return from Bang!adesh. Looking back, I
do not believe the story about his father being unwell was at all true nor do I believe he had . .
travelled to Bangladesh, as _h e had claimed, to t�ke money from me. He used the money to pay
Michael Olasende of SJ Solicitors to instigate a Court proceeding against me.
Later, in 2010, using the money he had taken from me as part of the agreement as above, Elias
instructed Anthony Hemmings of S J Solicitors in llford, IG3 . 9SQ in order to claim a 50% share of
_.th¢ whole Keppel Road properties as· he was a registered joint owner. I disputed this as· he had
only ever invested j ust under £3k in the property development. The matter dragged on through
the courts and it came before J udge May QC (Her Hon) in 2014. A four-day hearing was booked
but I did not attend at first as I had been· told by my solicitors that the hearing was not going ahead
due to the other side not complying with various directions orders from earlier hearings by his
Honour Judge Hornby. However, on the morning ofthe_hearing J udge May phoned me and asked
why I wasn't in attendance. I got straight into a taxi and went to the court. I was given a court
bundle, which was the first time I had ever s�en a court bundle as I had no experience of this.
Judge May QC (Her Hon) noticed I was struggling and stopped the hearing and adjourned it for
one day to allow me to familiarise myself. I then arranged for a barrister to attend and have my
witness statement submitted, which included what had always been my case a� above, The other
side then made an application for my witness statement to be debarred and for me to be debarred
to take part in the proceedings. U nfortunately, this was successful, so I didn't get to explain my
side of things. The c;,utcome of the hearing was that he was given Flat 1 and further awarded 50%
share of 2AKeppel Road. It was ordered to be sold and the other party asked to be awarded the
conduct of s_ale. Instead, Elias held oh to the property and then claimed the rent on the flats and
the unit by creating fake leases between me and his brother to say that his brother had paid me
rent for the commercial unit, Flat 3, Flat 4 & Flat-5. Rent for commercial unit 1 was at a rate of
£ 1 8,000 per annum. In addition, he then claimed rent for an additional commercial unit, the Unit
2 at a rate of £7200 per annum. This unit did not even exist, but using my debarment as an
opportunity, Elias made �p the whole unit to inflate his rent claim against me. Rents for Flats 3, 4
& 5 were claimed at £1 000 per flat per month from January 201 0 until March 2016. Elias using
various bogus documents, had presented a rent claim for total sum of around £240,000.00
He aue·ged I had lease agreement with his brother and his broth e r had paid me rent of which he
was entitled to 50%. It went to court but, as I had been debarred from the proceedings and
couldn't give my side, he was awarded the rental claim of £1 1 9,000, plus interest of £13,000,
plus legal costs to be decided. This claim is· the basis of the petition debt, which ultimately
increased to £391 ,000.
In the meantime, I .g rew increasingly suspicious of his solicitor and their activities and endless lies
• that they presented b�fore Court at every opportunity. I complained to the Solicitors Regl!lation
Authority. I complained, amongst other things, that Anthony Hemmings (aka Michael Olasende)
had submitted fake leases with fake signatures to the. Land Registry. Later, he had attemptep to
rec�ify this lease with further amendments, but these were rejected by the Land Registry. We have
••
only di_scovered these activities that had had gone on behind the seen� only recently.
After months of persuasions, I met up with an SRA investigator. Based on my complaint the SRA
finally decided to investigate the firm, SJ Solicitors, and the people behind the firm. Th�y later
discov_ered thaf Anthony Hemmings di9 not exist, and his real name was actually Michael Adewale
Olaseinde who had become a solicitor in 1 997 but had been ° struck off when he stole around
£17m of his client's _funds. He had th set up the firm of SJ Solicitors in llford using Kuldip Singh
as a front and carrie n with his tivtties as usual under the banner ·of SJ Solie;· ors. Business
Date: ______1_
?_J_
u_ e_
n_ 2_
0_1 ____
2_
--------------------------� - - • -- •• •
28
RE: Mohammed Kamal Ahmed Narrative page 3 of 4·
was as usual as before as far" as Mr Olaseinde was qoncerned. Anthony Hemmings was struck
off again due to this case along with the principal of SJ Solicitors Mr Kuldip Singh in March 20 1 9 .
SJ Solicitors were forced to close in June 2017 following an SRA intervention.
. .
Mark Jones, who is currently the barrister for Elias Hussain has been a barrister all throughout
the case and has attended every single hearing for him since October· 2012. He had worked in
the same firm as Michael Olaseinde in the past and where Olaseinde had been caught stealing
• but Mark Jones had evaded the net. I believe Mark Jon es had changed his__name and somehow
became a barrister and escaped/ evaded the SRA and other regulatory bodies ever since.
• I reported the activities of Mr Mark Jones to the Bar standards board without any success as
they dismissed my complaint as fanciful. I do believe Mr Mark Jones and Mr M·ichael Olaseinde
a re connected to each other and have been working together for years going back -as far back
as 1 995. I believe they have done this type of legalised robbery for many years and operated
initially in the Hertfordshire area until Olasende was caught and struck off by SRA
After the SRA findings were concluded in 2 01 9 I made an application in the High Court for the
whole •hing to be d ismissed due to fraud. There was a heari n g on 1 9 November 2020 which the
judge dismissed due to being out of time. I am looking at appealing in the Supreme Court. I
believe Elias has made me bankrupt to cut me out of these proceedings as Elias, Michael
Olasende and Mark Jones realise that if my appeal is successful then the alleged petition debt •
for which I have been made bankrupt will disappear and instead they would owe me money.
I have evidence to $how Elias' brother is impecunious (i.e. on benefits) therefore he could not
have paid me any rent as claimed by Elias in Court under oath before Judge, DJ Lightman on 29
March 2 01 6. In paragraph 31 .6 of his witness statement, dated 2 November 2 01 8 , Mr Elias
Hussain states "It is admitted that Enamul receives some state benefits in the form of Housing
benefit to augment his income and to assist in the provision of accommodation for himself and
his family". In this witness statement he also states in paragraph 72.2 "It is admltted that no rent
was paid by Enamul". Also, I have evidence from DWP that Elias and his wife Hafs� Khatl.in has
been claiming ho4sing benefit on 2.40 Monega Road, London, E12 6TS for a number of years and
since its inception.
Nigel Smith is the solicitor that contacted Mrs Brooker regarding these proceedings however I
don't believe he exists in the sense that he is the real solicitor that acting for Elias. I believe it the
M ichael Olaseinde is still pulling the strings from behind the scenes and uses Nigel Smith as a
front, just as he did before with SJ Solicitors Where he had used 'Kuldip Singh as a front. The
reason I say this us due to the· fact that, after SJ Solicitors were closed down, the file handlers
. working at SJ Solicitors had all moved to work for C_a rtwright ·c unningham Haselgrove & Co
(CCHC). Rozia Ali, a qualified solicitor who worked for SJ Solicitors, moved all the files including
the Elias file to CCHC. I believe Michael Olaseinde also moved under the banner of CCHC and · it
is MichaelOlaseinde still running the cases under the d isguise of Nigel Smith. . I request the OR
to call CCHC and to try to speak to Nigel Smith to establish the veracity of this statement and ask
him questions related to the background of this case. I n my experience of last few years I have
never managed to speak to him over the telephone. He has been an illusive man that never comes
on the phone and hides behind emails which I believe aren't written by Nigel Smith but rather by
Michael Olasende.
Michael Olasehde, Mark Jones, Kuldip Singh and Nigel Smith, Rozia Ali are part of an organised
white-collar gang that gets people wit sets and, using the law to their advan age; they slowly
1_J ne 0 1
Date: _____? _
u___
2_2______
-----------'-------------- - - -
- ·· ··- ····· .
29
RE: Mohammed Kamal Ahmed Narrative page 4 of 4
strip the victims of all their assets. By the time a victim realises what has just happened and works
· out their game plan, it is often too late as the Court and the systems simply dismisses victim's
complaints as out of time and with the excuse of finality. This gang have worked . out the system
and they are making full use of the system to rob hundre ds of people of their assets and life's last
possessions. •
Dabir's name was added as a counter claimant during the rent claim proceedings because he
• had a beneficial interest in Keppel Road as he had funded 50% of the purchase. The claim was
brought against myself, St Martin'.s Properties UK Ltd, Dabir and London Sorough of Newham
(merely for disclosure purposes). When the other side obtained the £ 1 1 9k rent claim judgement,
they made a Money Claim application to enforce it, but dropped St Martin's Properties UK Ltd,
which just left myself and Oabir. Dabir started his own claim against these proceedings and made
an application to set the judgement aside as he had nothing to do with the rent claim. The County
Court rejected it, so it went to appeal at the High Court. However, the judge said Dabir shouldn't
have started the defence in the first place as he wasn't liable, and had wasted the court's time .
. The judge then awarded £56k of costs against him. The £391 k petition debt includes this £56k
which is owed by Dabir and not me. Therefore, I am only liable for £335k.
. .
Dabir transferred his interest in two of our properties, 307 Katherine Road and 1 1 2 Strone
Road, to the other's party's solicitors and they were sold 2 weeks prior to the bankruptcy
hearing. These sales yielded enough proceeds to d ischarge my debt of £335k, therefore I do
not owe any monies, and in fact I am due around 5k back. •
I am now i n the process of taking advice to have the bankruptcy order annulled qn the basis that
the debt was not ciwed and the order should ought not have been made. I liave instructed a
solicitor and will be making the application as soon as possible.
I attribute my insolvency to a disputed debt.
I have no objection to a copy of this statement by anyone appointed by my trustee.
I acknowledge that I have carefully read over this statement, which is true to the best ·of my
knowledge, recollection and belief.
/?2 �
, -,j�"-.J...1...
Examiner: ___-...,. vJc-=--------'--
1 7 Ju n e 2 02 1
Date: _______________ __
30
THE OFFICIAL RECEIVER'S REPORT UPON THE BANKRUPT'S APPLICATION
FOR ANNULMENT PURSUANT TO SECTION 282 ( 1 ) (A) OF THE INSOLVENCY
ACT 1 986
I N THE HIGH COURT OF JUSTICE

BUSINESS & PROPERTY COURTS OF ENGLAND & WALES
INSOLVENCY & COMPANIES LIST (CHANCERY DIVISION)
BR-2020-0001 02
IN BANKRUPTCY
IN THE MATTER OF MOHAMMED KAMAL AHMED
AND IN THE MATTER OF THE INSOLVENCY ACT 1 986
REPORT OF THE OFFICIAL RECEIVER

Adjourned Annulment Hearing: 28 Jan uary 2022 1 0 :00AM
1. I , Majeda Khatun, a Deputy Official Receiver, am authorised to file this application

and report on behalf of the Official Receiver, Joseph Sullivan.
2. A Bankruptcy Order was made on 24 May 2021 in the High Court of J ustice upon
the petition of Elias Hussain which was presented on 30 January 2020.
[MK1/Doc1/pg. 1 ]
3. The Official Receiver i s trustee of Mr Ahmed's estate.
4. M r Mohammed Kamal Ahmed attended upon the Official Receiver by telephone on

1 1 June 2021 and 9 July 2021 and provided information on his current assets and
liabilities.
Assets
5. The Land Registry shows that Mr Mohammed Kamal Ahmed is joint owner, with his
brother Dabir Nozrul Islam Ahmed, of the following properties:
a. 41 Rothsay Road, London E7 8LY - currently tenanted

b. 2 Keppel Road, London E6 2BD - currently tenanted
c. 2 1 4 Plashet Grove, London E6 1 DA - Mr Dabir Nozrul Islam Ahmed is
currently resident in this property
d. 1 7 Bristol Road, London E 7 8 H G - currently tenanted
e. 48 S haftsbury Road, London E7 8PD - currently tenanted
f. 25 Rothsay Road, London E7 8LY - currently tenanted
31
g. 1 97 Plashet Grove, London E6 1 BX - Mr Mohammed Kamal Ahmed is
resident in this property
h. 43 Rothsay Road, London E7 8LY - currently tenanted
6. The value of Mr Mohammed Kamal Ahmed's equity in these properties, all of which
are subject to secured charges, is as follows:
41 Rothsay Road, London E7 8LY £ 1 47,697
2 Keppel Road, London E6 2BD £ 1 07 , 9 1 5
214 Plashet Grove, London E6 1 DA £1 54,800
1 7 Bristol Road, London E7 8HG £1 27,708
48 Shaftsbury Road, London E7 8PD £1 80,272
25 Rothsay Road, London E7 SLY £ 1 53 , 1 72
1 97 Plashet G rove, London E6 1 BX £201 ,370
43 Rothsay Road, London E7 SLY £144,420
Total £1,217,354
17 Two further properties, 307 Katherine Road, Forest Gate, London E7 8PJ and 1 1 2
Strone Road, East Ham, London E7 8ES, were sold via a successful application for
a n Order for Sale by the petitioning creditor prior to the making of Mr Mohammed
Kamal Ahmed's bankruptcy order.
18 M r Ahmed has provided the Official Receiver with a copy of a trust document, dated
28 May 2008, that shares the beneficial interest in these properties between Mr
Mohammed Kamal Ahmed and his siblings Afia Begum Ahmed, Dabir Nozrul Islam
Ahmed, Hazrat Fatema Bibi, Kabir Ahmed and Begum Sufia Ahmed. [MK2lpg.2-8]
19 The trust document, the legality of which has not been verified, details the split of
the beneficial interest in the properties as follows:
Dabir
Noszrul Mohammed Hazrat Begum Afia
Islam Kamal Fatema Kabir Sufia Begum
Ahmed Ahmed Bibi Ahmed Ahmed Ahmed
41 Rothsay Road, London E7 SLY 20% 0% 20% 20% 20% 20%
1 1 2 Strone Road, London E7 SES 95% 5% 0% 0% 0% 0%
2 Keppel Road, London E6 2BD 5% 95% 0% 0% 0% 0%
2 1 4 Plashet Grove, London E6 1 DA 0% 0% 0% 0% 50% 50%
1 7 Bristol Road, London E7 8HG 5% 95% 0% 0% 0% 0%
48 Shaftsbury Road, London E7 8PD 0% 20% 20% 20% 20% 20%
25 Rothsay Road, London E7 SLY 0% 0% 0% 0% 50% 50%
1 97 Plashet Grove, London E6 1 BX 0% 0% 1 00% 0% 0% 0%
43 Rothsay Road, London E7 SLY 0% 0% 0% 1 00% 0% 0%
307 Katherine Road, London E7 8PJ 95% 5% 0% 0% 0% 0%
32
20 The Official Receiver has been provided with a copy of a sealed order, in relation to
the properties in paragraph 1 7, dated 20 February 2020, given by the Honourable
Mr Justice Waksman. The judgement states:
"Today, Wednesday 19 February, I was asked by [Dabir Nozrul Islam Ahmed] to

stop the sale on the basis that in truth, as between [Mohammed Kamal Ahmed] and
him, they shared the beneficial interest in both properties as to 95% for [Dabir
Nozrul Islam Ahmed] and 5% as to [Mohammed Kamal Ahmed]. This was said to
be based on to express declarations of trust produced to me dated 2006 which do
not appear to have made any appearance in the very numerous hearings
concerned with the sale of both properties previously.
If there was anything in this argument, it is inconceivable that it would not have
been raised from 1 November 201 7 onwards when the 1st order for the sale of
Katherine Road was made pursuant to the obtaining of final charging orders in
respect of monies owed to the Claimant. Further orders were made in 20 1 8 and
2019, and yet, again, it was never suggested that there should be a carve-out for
{Dabir Nozrul Islam Ahmed's] beneficial interest. [Mohammed Kamal Ahmed]
informed the court that [Oabir Nozrul Islam Ahmed] took the same position as him
and on one occasion Counsel appeared at least for [Mohammed Kamal Ahmed]
and possibly [Oabir Nozrul Islam Ahmed] also. Indeed, neither was this argument
raised in the 1st paper application which I dealt with yesterday. In those
circumstances, there is no basis for now granting a "without notice" order the effect
of which is to stop the sale of the properties at an auction, more than 2 years after
the 1st allegedly erroneous order for sale was made". [MK3lpg.9-1 OJ
21 I n a letter from the petitioning creditor's solicitor, Nigel Smith of Cartwright

Cunningham Haselgrove and Co, dated 1 5 June 202 1 , the proceeds of sale from
307 Katherine Road and 1 1 2 Strone Road were £1 77,990 and £ 1 64,065
respectively. As the Land Registry shows Mr Moham med Kamal Ahmed and Mr
Dabir Nozrul Islam Ahmed as joint owners, £88,545 and £81 ,532 (totalling
£1 70,077) has been retained by the petitioning creditor's solicitors to partially settle
the petition debt. [MK4lpg.1 1 -1 2]
22 Mr Mohammed Kamal Ahmed has scheduled further assets in his PIQB

questionnaire as follows:
a. Income from rental properties - Mr Mohammed Kamal Ahmed advised i n

an email of 1 5 August 2021 [MKSlpg.1 3-1 5] that he a n d Mr Dabir Nozrul
Islam Ahmed receive an equal share of the net income from the six
properties that are currently tenanted. According to Mr Mohammed Kamal
Ahmed, the managing agents are Alexandra Levi Ltd, of which the sole
director and owner is Begum Sufia Ahmed, sister of the joint owners. The
net rental income, after fees to Alexandra Levi Ltd of £ 1 ,650 per month
have been paid, is £ 1 , 6 1 4 , which is paid into Mr Dabir Nozrul I slam
Ahmed's bank account. 50% of the net income of £807 is then paid to Mr
Mohammed Kamal Ahmed. The Official Receiver wrote to Mr Mohammed
Kamal Ahmed on 9 August 2021 [MKGlpg.16-17] and 7 October 2021
33
[MK7/pg.1 8-19] and requested that he pay this income over into Official
Receiver's bank account. As at the date of this report, no monies have
been received.
b. Insurance policies - a life insurance policy with Royal London and a life
insurance policy with Canada Life have been declared. O n 22 September
2021 Canada Life advised that the policy is no longer in force. As at the
date of this report, it is not known if the Royal London policy has any
surrender value.
c. Cash in bank - £7,600.56 has been remitted to the Official Receiver's

bank account from Mr Mohammed Kamal Ahmed's Santander account. A
further cash sum of £5,320.88 is due to be remitted from Mr Mohammed
Kamal Ahmed's Lloyds bank account, however, as at the date of this
report, the funds have not been received into the Official Receiver's bank
account.
d. Shares - The Official Receiver is aware that has shares that were valued
at £973.86 on 1 0 July 2021 . These shares have not yet been realised for
the benefit of the bankruptcy estate.
Liabilities
23 The following are the liabilities known or notified to the Official Receiver:
Unsecured creditors Amount Amount notified Comments

scheduled by to the Official
bankrupt Receiver
Anisah Tariq £1 70,143 - Personal loans
Bank of Scotland £87,260 - Mortgage shortfall
Beaum S ufia Ahmed £240,608 - Personal loans
Dabir Nozrul Islam Ahmed £ 1 ,943,151 - Personal loans
Elias Hussain - £221,591 Various iudaements
Hazrat Fatema Hussain £71,579 - Personal loans
HBOS 30 30 Personal loan
Muhammed Kadir £25 , 1 72 - Personal loans
Pro 2 Medical (UK) London Ltd £5,034 Leaal costs
HMRC - £1 1 , 078.67 Self-assessment tax
24 The total value of the stated and claimed u nsecured debts amounts to £2,775,647,
of which the proofs of debts have been received from the petitioning creditor, Pro 2
Medical (UK) London Ltd and HMRC.
25 The Official Receiver is satisfied that Mr Mohammed Kamal Ahmed has complied
with his d uty to attend upon the Official Receiver and provide information on his
assets and liabilities. However, he has not paid over any income from the rental
properties to date.
34
26 After the submission of the report for the 1 7 September 2021 annulment hearing,
which was copied to Mr Mohammed Kamal Ahmed on 25 August 202 1 , Mr Ahmed
contacted the Official Receiver by email to state that the report was " Factually
inaccurate . . . biased. . .painting (sic) a inaccurate Picture of the circumstances
favoring the Petitioner" and that he felt that the "statement was prepared with the
premeditated intention of persuading the Court for my annulment application to faif'.
The Official Receiver responded to Mr Ahmed to request that he provide specific
information on any inaccuracies so these could be added to the report. However, as
at the date of this report, no further correspondence has been received on the
matter. [MKSlpg.20-21]
27 On 30 September 2021 [MK9lpg.22] and 1 2 October 2021 [MK10lpg.23-24]the

Official Receiver received emails from Gareth Bishop of McAlister & Co, licensed
insolvency practitioners, advising that they had been contacted by Mohammed
Kamal Ahmed in relation to him seeking to annul his bankruptcy on the grounds that
his creditors had approved a proposal for an individual voluntary arrangement. As at
the date of this report, the Official Receiver has not received any further
correspondence on the matter.
28 On 2 October 2021 the Official Receiver received an email from Mohammed Kamal
Ahmed requesting a copy of the petitioning creditor's proof of debt. He stated, "In
addition £12, 000 security has been added to 4 1 Rothsay Road on 29.09.2021
against Dabir's Interest. I will forward you the order when I receive it. This £12, 000
formed part of the petition debt and therefore must fall away from my debt as it is
secured now". The most recent available copy of the title from the Land Registry
does not show that this security and, as at the date of this report, a copy of the
order has not been received. [MK1 1 lpg.25]
29 In the same email of 2 October 202 1 , Mr Mohammed Kamal Ahmed requested that
the Official Receiver contact the petitioning creditor's solicitor "Nigel Smith and find
out under oath, how much security he has and against what". A response was
emailed to Mohammed Kamal Ahmed, attaching a copy of the petitioning creditors
proof of debt, advising that " The Official Receiver's role is not to prove the debt is
owed, there has already been an order made by the judge sitting at the bankruptcy
hearing in that regard, therefore we will not be seeking to examine Mr Smith under
oath". [MK1 2lpg.26-28]
30 On 14 January 2022 the Official Receiver sent an email to Dabir Nozrul Islam
Ahmed advising of his intention to ask the Secretary of State to replace him as
trustee with an Insolvency Practitioner. He was asked if he wished to nominate a
new trustee and that the deadline was Friday 21 January 2022. He replied
requesting an extension to this deadline, however this was refused. [MK1 3lpg29-
30]
31 Should it be established that the above assets in paragraph 6 are not subject to a
family trust, Mr Ahmed has known liabilities of £2,764,538 and potential assets of
£1 ,21 7, 354. The decision on whether or not the bankruptcy should be annulled on
the basis that it ought not to have been made is a matter for the court to decide.
35
32 Mr Mohammed Kamal Ahmed application is on the basis that the order ought not to
have been made therefore the Official Receiver requests that the Court make a n
order for costs in the matter. Based o n a time and rate calculation the Official
Receiver's costs are £2,269.50. It should be noted that, as at the date of this report,
£7,600.56 has been received from M r Ahmed's bank account.
M�
Majeda Khatun
Deputy Official Receiver
1 8 January 2022
36
Questionnaire
Deed of Trust dated 2 8 May 2008
1 Was the deed prepared by s o l i c i t o r s , i f so who? Please provide their full

contact d e t a i ls . I t i s reasonable t o as sume that the i r f i l e will by now have
been des t royed . Do you have any l e t t e rs or emai l communications from them
verifying the i ns t ructions they rece ived or the advice they gave or indeed simply
verifying the i n st ructions they received or the advice they gave or indeed simply
veri fying the date at t r ibuted to the docume n t ?
REPLY :
A. We are not I 00 %. Our family that included our father and the uncles were a traditional joint
family from Indian Subcontinent. They conducted their business together between brothers
including their cousins and were into various business including property business. With the
proceed from the business they had bought properties for the family and left the properties for
the children.
B. We have made attempt to find out hovv this Deed was constructed and the information that we
have come to know is that this deed was prepared by a family friend, called Mr Jimmy Yamphet.
I have been in touch with him recently he confirmed the same. He explained, he had another
friend John that had similar deed for his own family which was drafted by a solicitor based in
London, Katherine Road , High Street North area. He couldn't recall the name, but knows they
are no longer there as the Solicitor has retired and moved to Canada some years back. When our
parents had discussed the matter with Jimmy, Jimmy offered to draft this using the template
from John. This is how this deed had come about.
C. Jimmy's contact details are as below:
Address : 26 Luton Road , London, E 1 3 8HD
Email address: jimmy.vamphet@gmail.com

Jimmy conformed he was there when the deed was signed and witnessed by John.
D. He explained it was done for the purposes of the family's children so that know whos owned
what and what share. It was not done for it to be used the current context. Our family had
never been involved in any type of litigation or court cases before. Court cases / Litigation
f, te· M2.90C A 22-.3·2022 CPCPCP Quest1 onnc11tc.doc
37
are not seen with good light in the community so no one would have anticipated for it come
to this. One wrong friendship by Mohammad and our entire family is dragged into this.
2 . I f the deed of trust was not prepared by solicitors, then who was it prepared
by? Do you have any corre spondence or ema i l s from the party who prepared the
document confirming the i n s tructions they received, the advice they gave or
indeed simp l y ve ri fying the date a t t r ibuted to the document?
REPLY :
The wording the layout was already drafted by a solicitor for John and his family. When our parents
discussed the matter with Jimmy , Jimmy used the same draft to create one for our family. The
allocation of share was decided by the family elders. As to the rationale behind the allocation of
shares are only known to them. We have no idea why a certain percentage was given to certain
people.
3. Other than the par t i e s to i t , including the witness, can any other third
party, especially a profe s s i onal adviser or former profe s s i onal advi ser,
verify its terms and the date a t tributed to i t ?
REPLY :
The only person that we know that can verify the deed is Jimmy Yamphet.
4 . Was the document presented for s tamp duty purposes?
REPLY :
We do not know.
5 . What was the purpose of the deed of trust and why the shares attributed to who
they were and why to those proper t i e s ?
REPLY :
The True intention as to the purpose of the Deed and why the shares attributed in the way they were
is not known to us. We can only assume; the purpose was to give everyone an equal share of the
asset. If you look closely on the share attribution then you will note , everyone ended up with the
similar shares overall. In other words everyone ended up with same equal shares albeit attributed to
different properties but if you add them up then you will note, all adds up to same shares.
6 . To what extent have the parties contributed to the purchase or the upkeep of
any of the properties referred to therein?
REPLY :
38
Generally, as a part of the entire entity they are involved in day to day management, maintenance of
the properties where everyone gives their time equally in maintaining the properties as much as
possible in between their personal and professional lives . It is not set in stone, but everyone gives
their time as much as possible. They do it more as a help for the family then doing it for themselves.
Even if we were not given the share of the asset , we would have done exactly the same where we
would have offered our help where it was needed whenever it would have been needed.
7 . To what extent have any of the parties referred to therein been in occupation
of any o f the properties referred to therein and if so for what dates ( i ncluding
current ) and upon what terms - is full commercial rent being paid subj ect to a
tenancy agreement .
REPLY :
1. These properties are all used the purposes of benefiting everyone within the family . 2 1 4 Plashet
Grove is a the family main house where we all Grew up pretty much. When the family grew
bigger , some member of the family then moved to across the road in 1 97 Plashet Grove. When
I say they moved to 1 97 Plahset Grove, I mean they only use it to sleep there, the cooking as
still done at 2 1 4 Plashet Grove and everyone eats at 2 1 4 Plashet grove. When extended family
visits , they visit 2 1 4 Plashet Grove as the family's main hub and not 1 97 Plashet Grove. The
girls of the family had moved out one by one when they had married but the family stayed as
one joint family. It's a one family entity.
11. Any proceed generated from the prope11ies are used by all to subsides their own respective lives.
For example, as an elder boy in the family DNA buys everyone their cars and pay for the
maintance of the cars. DNA also pay everyone's insurances as well as everyone's mobile phone
bills. We use the proceed to fund the family's yearly holiday together and for whatever big
expenses they need to make. Everyone dips into the money if and when they need it so long as
the money available. We do not mix any funds with our own personal funds that we earn
through employment or other means. We do not follow a set rule of share. We just all discuss
and share the proceed for the ones that needs the most. We appreciate the fact that this is very
unusual process in these day and age but this is how we have operated for almost 3 generations
or at least as long as we remember it.
8. What i s the date of birth of the parties to the deed of trust?
A. Dabir Nozrul Islam Ahmed , DOB - 07 Jan 1 972

B. Kabir ahmed , DOB - 28 July 1 970
39
C. Begum Sufia Ahmed , DOB - 22 Nov 1 972
D. Afia Bgum Ahmed DOB - 0 I Jan 1 974
9. What i s the r e l a t i onship between the part i e s ?
REPLY :
I. Mohammad Kamal Ahmed and Dabir Nozrul Islam Ahmed - Brothers

2. Hazrat Hussain - is a cousin to Mohammad and Dabir
., . Begum Sufia - Is a cousin to Mohammad and Dabir
4. Kabir Ahmed - is a cousin to Mohammad and Dabir
1 0 . Are any of the part i e s known by any other name or a l i a s ?
REPLY :
No
11. Can you l e t us have the names of any spouses t o the parties to the document?
REPL Y :
Name Spouses
Mohammad Kamal Ahmed Dr Sufia Sewn
Dabir Nozrul Islam Ahmed Hajera Begum Ali Ahmed
Kabir Ahmed Jesmin begum
Hazrat Fatema Hussain Single
Begum Sufia Ahmed Widowed
Afia Begum Ahmed Mr Koysor Ali
12 . Where i s the ori ginal deed o f t r u s t ?
REPLY :
With the eldest in the family, she has since moved back to Bangladesh for her retirement.
13. When was the deed o f trust f i r s t known t o o r disclosed t o Alias Hussain?
REPLY :
40
1. It was never disclosed to Mr Elias Hussain directly and the reason never arose for it to be
disclosed. The family trust deed had always been known to everyone that knew the family. Elias
knew the fami ly well and he would have known about it. And it had been mentioned at times
whenever there was a talk of any family asset. The deed had been talked about in the court and
Elias' s Solicitor and barrister had accepted the existence of the trust deed. Pleadings ( skeleton
arguments ) relied upon by other side refers to the Trust Deed whenever the talk of family asset
had been discussed and copy had been flying around from the outset.
ii. He had nothing to do with the family and these properties. He is not party to the family asset
and the properties within had nothing to do with him. The dispute with Mr Hussain was over a
completely separate propertv not connected to these properties at all. The dispute with Mr
Elias Hussain was over 2A Keppel Road that was purchased by Mohamamd Kamal Ahmed and
elias Hussain in July 2007 in joint venture for the sum of £425,000
i ii . In the year 2006 MKA became interested in a property of 2 and 2A Keppel Road on the
introduction of Elias. Elias persuaded MKA to join in the purchase of 2 and 2A Keppel Road.
An oral joint venture with MKA, DNA and Elias for the purchase of 2 and 2A Keppel Road,
East Ham, London E6 2BO was formed. Pursuant to the joint venture 2 Keppel Road,
comprising two residential flats, was purchased by MKA, DNA and Elias and 2A Keppel Road
was acquired by MKA, DNA and Elias. A non-binding Memorandum of Sale was signed and
a holding deposit of £ 1 ,000 paid in November 2006 to the sellers. Completion was on 2nd July
2007 and MKA, DNA and Elias were registered as proprietors of the two properties on 25
September 2007. E l ias had failed to come up with any money except a contribution of just
£2,984. Mohammad should have known better as Elias was known to everyone and his financial
ability was very clear and before agreeing to but the property on 50:50 basis Mohammad should
have known that Elias did not have the means to pay for it.
iv. Once the property was purchase it 'vvas developed at cost of over £ 3 1 9.000. This money was lent
to MKA by DNA and other members of the family. The deal was that Elias Hussain will soon
find money to and his contribution equal but he never did. He created one excuse or other and
never came up with the money. In the hindsight, he never had the intention to make his
contribution equal. He was in it for the free ride. He effectively became 50% beneficial owner
of2A Keppel Road and 1 00% owner of the Flat I with a less than 1 % contribution.
41
v. Once developed the property was Mortgaged with Bank of Scotland for the sum of £358,000.
Elias took half the money and never accounted for the shortfall of his contribution. Because the
property was in 2 names, the solicitor at the time advised both that he could only transfer the
money equally between the parties. The deal was that upon receipt of the money from the
Solicitor, Elias will send the money to Mohammad but he never did except a sum of £25,000.
Elias walked away with half the loan from Bank of Scotland.
vi. Elias left the office from which he operated with MKA and DNA in about January 20 1 0 when
the Claimant discovered defalcations on the part of Elias in relation to rents collected and
deposits paid by tenants. The joint venture broke down in 201 0 and following legal proceedings
between MKA, DNA and Elias, in the Central London County Court, HH Judge May QC held
on 29 August 2 0 1 4 (the "May Judgement") that the freehold of 2 Keppel Road was held for
MKA and DNA as to 50% and by Elias as to 50% as tenants in common.
v11. It was also held that 2A Keppel Road was held as to 50% by MKA and by Elias as to
50% as tenants in common beneficially. Elias had only contributed 2.3% towards the purchase
of2A Keppel Road and its development, while Claimant and MKA contributed remaining 93.7
% of the total.
v111. Prior to the hearing before H HJ May Elias's then fake solicitor Mr Anthony Hemmings
made an application to debar MKA and as a result he was debaiTed from submitting a witness
statement or giving evidence at the trial before HHJ May due to the negligence of his then
solicitors which lead to Elias being awarded 50% beneficial share of 2A Keppel Road.
ix. Further and in addition, Elias Hussain had never paid a penny towards the Mortgage with Bank
of Scotland where MKA had paid a total of £ 1 46,000 towards the mortgage payment from the
inception of the mortgage in 2008 unti I the property was sold.
START OF FRAUD: PETITION DEBT ARE FRAUD IN ITS ENTREIRTY
x. Elias before DJ Lightman on 29 March 20 1 6 presented a fake lease agreement between him and
his own brother , Mr Enamul Hassan ( ELH ) and claimed that his brother Enamul Hasan had
been paying rent for the disputed property since 2009 and he continued to pay the rent. Elias on
Paragraph 37 of statement signed \vith a Statement of Truth , dated 07 August 20 I 5 Stated "
Rent was paid in 2009 and there is 110 reason for it not continue thereafter"
42
x1. Using this false rent claim leas was awarded a rent claim o f £ 1 1 9,000 plus interest plus cost By
DJ Lightman on 29 March 20 1 6. This has now become the judgement debt.
MOHAMMAD WAS DEBARED FROM DEFENDrNG THE FALSE RENT CLAIM:
x11. Earlier using a fake solicitor called Anthony Hemmings, Elias made an application for
debarring Mohammed from Defending the Account hearing before DJ Lightman. This fake
solicitor , whose real name is Michael Olasende had been struck of for fraud in 2007. He lied
that Mohammad did not comply with the earlier order for account hearing and was saucerful
with his application to debar Mohammad from Defending the claim for rent.
xiii. Michael Olasende's fraud was later discovered by SRA. Please see link below
xiv. Using the Debarment to their ful l advantage the advanced a totally fictitious rent claim.
Which later they have both admitted to be false.
SEP ARA TE PROCEEDINGS BY DNA ( CLAIM NUMBER E02CL879):
xv. On 1 9.09.20 1 8 the Second Defendant (MKA's brother Dabir Nozrul Islam Ahmed) issued
fraud proceedings against the C laimant Lmder the action no E02CL879 !EXHIBIT 6J.
xvi. The Defendants Mr Elias Hussain and his brother Mr Enamul Hasan served a Defence on 02
November 20 1 8 with Statement of Truth " I believe thatfacts stated in this Defence are true"
[EXHIBIT 71
XVII. Paragraph 62.1 where the Claimant and his brother had stated in their defence:
xviii. " In the course ofapplyingfor mortgagefinance as pleaded in paragraphs 44 and 45 ofthis
Defence, MKA and Elias were advised by Mr Singh, a business development manager in the
employment of the Bank that Bank of Scotland wished to see a commercial lease of Unit I
"
xix. Paragraph 62.2 where the Claimant had stated in their defence:
" MKA and Elias agreed to enter into a commercial lease with Enamul, intending that such
lease would or may be assigned to SMPUKL once the mortgagefunds fwd been drawn down ".
43
xx. Paragraph 64 where the Claimant's defence had stated:
" It is admitted that the lease was not exhibited to Elias 's statement preparedfor the purposes
ofthe account, as specifically adverted to in paragraph 37 ofthat statement, but it is admitted
and averred that the deed of rectification and licence was exhibited to his witness statement
as alleged in paragraph 13" Paragraph 66 where the Claimant had stated
xx 1. " It is admitted that Enamul paid 110 rent in respect Unit 1 from the date of the grant of the
lease until its assignment, or thereafter"
XXII. Paragraph 72.2 where the Claimant had stated:
" It is arln1itte(/ that 110 rent J-vas paid bJ' E11an111/ "
Paragraph 72.5 where the Claimant had stated:
" Elias admits that 110 rent had been paid by Enamul as aforesaid ".
ENFORCING THE JUDGEMENT:
1. Elias then took charge orders against the family properties and proceeded to sell them.
DISCLOSURE OF TRUST DEED:
Elias had been pa11 of managing family's properties for years. He had collected all rents and
distributed them accordingly from at least 2006. It had always been known to everyone that had
any association with the family. A copy was made available if and when the fam i ly asset was
discussed.
1 4 . To what extent , if at a l l , has the rental income been divided between the
part i e s ?
REPLY :
Please see earlier reply where I have briefly explained how the proceeds are shared and used for
the benefit of the family.
1 5 . The deed of trust expre s s l y provides for the r e g i s t e red proprietors to be

responsible for the mortgages secured against the property and the i r
repayment . That means they e s t ablish a disproportionate r i s k . What was the
rationale behind that arrangement and why were the other parties to the
agreement not required to indemnity the regi s t ered proprietors?
REPLY:
44
There is no rationale behind such arrangement and if one looks at with modern day western
system in mind , it would never make sense . It is family tradition for the boys to be responsible
for everything fair or otherwise. Having catered for the girls if it means boys go without then so
be it. Its an upspoken rule in the family and the wide community of the people from similar
background. Boys are expected to make the sacrifice whether it is financially beneficial or not.
Traditionally in an arrangement such as this the girls are almost a lways made to be better off.
This is because the girls are traditionally seen as vulnerable and therefore, they should benefit
more. The boys and particularly the eldest in the family are usually lumbered with everything.
It is more a reasonability thing then fairness. It is the responsibility of the boys take the control
of the realm whether is fair or otherwise.
16. Please let us have your tax returns for the l a s t 6 years and an authority
addressed to HMRC for the disclosure of all and any tax returns which have
been f i l ed by you whether personally or j ointly w i t h anothe r .
REPLY :
See attached
17 . Has the deed of trust been va ried in accordance w i t h paragraph 4 . 1 of i t s

terms ?
REPLY :
No , No , we never felt the need except that had our own unwritten agreement in place where
party gives their time and effort if and when required.
18 . Who i s John Frimdon, the witness to the document? Was he known to all o f
the parties or j ust some o f them? Where was the deed of trust executed and
was Mr Frimdon present at the t ime of the execution of the deed of trust by
all par t i e s ?
REPLY :
A. John Frirnpong was a friend of the fathers and uncles. It was executed in front of him yes.
1 9. Mr Frimpong is accredited w i t h an address at 1 2 2 Manor Road, London, Nl7

OJE - a l though the last part of this post code is unclear . I s Mr Frimdon
s t i l l at this address and i f he is cou l d you please clarify the full post
code? If he i s not a t this address then could you please provide a current
contact address for him?
45
REPLY :
Mr Frimpong was still at this address until he had died of Covid April 202 1 .
2 0 . Have any other prope rties been brought by Kama l / Dabir or indeed any o f the
parties to the deed o f trust whether or not they wer e int ended to be sub j ect
to the t e rms o f the deed of trust or not? If they have then please ident i fy
the purchasers and the full addre s s of the prope rties purchased . Was i t
intended for these properties t o b e the subj ect o f the te rms o f the deed of
trust and if not why not?
REPLY : No
Properties
General
2 1 . Would you please confirm whether Kamal i s married and i f so please provide
the full name of his spouse and any child over the age of 18 as at the date
of the bankruptcy order .
REPLY :
YES Married with 2 children.
2 2 . Please identify the usual place of res idence of both Kamal and his wife as a t
t h e date of the bankruptcy orde r . I f there i s any doubt a s to their usual
address at that time then please provide a full explana tion .
Reply :
l 97 Plashet Grove, east ham, London, £6 l BX
307 Katharine Road
23. Please provide :
(i) The most recent professional va luation of the property i n your pos s e s s ion
or control .
Reply :
This property was sold in an Auction by Elias Hussain. The sale completed on 1 9 May 202 1 . Prior
to the sale of the property the property was valued £468,000. But in the Auction it only attracted
£4 1 5,000 with a shortfall of at least £50,000 to £60,000. We blame this on the timing of the sale.
Elias had l isted the property to be sold in an Auction during the hight of the covid 1 9 pandemic
when all gathering were banned by the Govmment. This resulted in the Auction been held on line
only. The results were fewer people had logged to bid, leading to lower price fetched. We believe
had it been sold in the open auction then the true value would have been real ised. Mohammad had
been seriously prej udiced as result for the sum of At least £50,000 to £60,000
(ii) A copy, i f you have i t , o f the memorandum o f sale o f this
property.
46
Reply : Do not have , This prope11y was sold in an Auction by Elias Hussain. The sale completed
on 1 9 May 202 1
(iii) A copy o f the completion s tatement fol lowing the sale o f the property -
i f you have i t .
Reply : Please find attached completion Statement.
Not applicable, Lexmax had bought the property in an open Auction conducted by Stretton's.
Reply : cou s i n , Please see above .
( iv ) Confirmation o f the extent to wh ich, i f a t a l l , Kamal o r Dabi r are
entit led to an interest in Lexmax L t d .
Reply : None
(v) Confirmation of the extent to wh i ch , i f at a l l , Kamal o r Dabir have
guaranteed the current mortgage held by One Savings against the t i t l e
held by Lexmax L t d .
Reply : None , Lexmax is the new owner of the property.
( vi ) Please identify the persons currently in occupa t ion o f the property.

Please identify the date of the commencement o f their occupation and
provide a copy of the tenancy agreement regulating their occupation of
the property. Please iden t i fy the parties to whom rent i s paid and
provide evidence of the payment of rent for the l a s t 6 months . Please
can you give an account ( a lbeit that may be more general terms ) as to
the rental income received across the property portfolio and i t s
dist ribut i o n )
Reply :
It was sold in auction by the Mr Elias Hussain. Lexmax had bought the property in an open
auction. We are no longer in control of the propeI1y.
43 Rothsay Road
24 . Please provide :
(i) A copy of the most recent profes s i onal valuation you hold for the
propert y .
REPLY : Please find attached. Cun-ently the prope11y i s valued at in the region o f £400,000 to
£425,000.
(ii) The most recent redemp t i on statement you have from NRAM L t d . I f that
redemp t ion statement is more than 3 months old then could you please
provide an up-to-date redemption st at ement .
Reply: Please find attached. The latest Mortgage statement is attached. As the mortgage is interest
only , the figures would have remained the same until now.
47
(iii) A copy o f the interim cha rging order held by Elias Hussain secured on
6 Jul y 2 0 1 5 .
Reply : Please see attached

(iv) A copy o f any final charging order made i n favour o f Elias Hu ssain
arising from the interim charging order at ( i i i ) above .
Reply Please find attached

(v) Documentary evidence o f the tenants i n common restriction regist ered on
4 November 2 0 1 4 .
Reply : Please find attached.

(vi ) Please ident i fy the par t i e s t o whom rent i s paid and provide evidence of
the payment of rent for the last 6 months . Please can you give an account
( albeit that may be more general terms ) as to the rental income received
across the property port folio and its distribut ion )
Reply : The Property is occupied by Mrs Rani Begum and family.

The rent is paid to DNA.
197 Plashet Grove
2 5 . Please provide :
(i) The most recent profe s s i onal valua t i on you have for the propert y .
Reply :
Please find attached. The Property is currently valued at £450,000 - £470,000

(ii) The most recent redemp t i on st atement you have for the mortgages held by
Santander and Elderbridge Ltd . I f any such redemp t i on s t atement i s
more than 3 months old then please provide current redemp t i on
statements .
Reply :
Please find attached.

(iii) The charging orde rs secured by Elias Hussain dated 6 July 2 0 1 5 and 4
December 2 02 0 . I f e i ther of those interim charging orders have now been
made final then please do provide a copy of the final charging orders .
Reply :
Please find attached

( iv ) A copy of the charging order held by Arrow Global Ltd secured on 2 9 September
2 0 1 7 . Insofar as that interim cha rging order has been made f inal then please
do provide a copy of the final charging orde r . Please provide a short
explanation for the c i rcumstances in which this charging order was sought
by Arrow Global Ltd .
Reply :
48
We do not have a copy. We do not know, We have not been served with any papers. We will try
and find out and let you know accordingly.
( v ) A copy of the charging orde r secured by Merritt & Co on 6 March 2 0 1 9 . If
that inte rim charging order has now been made final then please do provide
a copy of the final charging orde r . Would you please also l e t us have a
short explanat i on of the ci rcums tances i n which that charging order c ame to
be secured by Merritt & Co .
Reply :
MK.A engaged with the solicitors firm Men·itt & Co in 2 0 1 7 when Elias made part 8 Application
to see the property of 307 Katherine Road and 1 1 2 Strone Road. She was instructed to oppose the
sale. She had agreed a set fee with MKA verbally for the sum of £5,000 to deal with the
application to sell. The Counsel fee was agreed and paid separately. Later she billed MKA for
extra hours that she couldn't have spent on the case as he had only worked for the firm just I day
a week. MKA subsequently paid her a total of £8, 1 98 but she was not satisfied with the additional
sums
She then issued Court proceedings for unpaid invoices under case number: E45YX782 at
Clerkenwell & Shored itch County Court. I defended the case, there was a cost order made against
me for around £5,000 around November 20 1 8, for which she must have obtained a charging order
for. I was not served with anything and she has somehow lodged it against the title of the property.
( vi ) A copy of the documents giving r i s e to the r e g i s t ra t i on of the tenancy in
common r e s t r i c t ion r e g i s t e red against the t i t l e to the propert y .
Reply : Please find attached

( vi i ) Please identify the persons currently i n occupation of the prope rty . Please
identify the date o f the commencement o f their occupation and provide a
copy of the tenancy agreement regulat ing t h e i r occupation of the prop e r t y .
P l e a s e identify t h e parties to whom r e n t i s p a i d and provide evidence of
the payment o f rent for the last 6 months . Please can you give an account
( albeit that may be more general t e rms ) a s t o the rental income received
across the property portfolio and its d i s t r ibution)
Reply :
Moahmmad Kamal Ahmed and family. No rent is paid.
25 Rothsay Road
(i) The most recent profess ional valuation you have for the proper t y .
Reply :
49
{ii) The most recent redemp t i on statement you have for the mortgage held b y Bank
of Scotland. I f that redemption s t atement i s more than 3 months old then
please provide an up to date redemp t i on sta tement .
REPL Y :
Please find attached. As the mortgage is on the Interest Only, nothing has changed since.
(iii) The charging order held b y Elias Hussain .
REPLY : Please find attached.

( iv ) The charging orders h e l d by Ivanna Sentenenko secured on 2 June 2 0 1 6
and l November 2 0 1 9 . Please ident i f y the ci rcumstances i n which that claim
was brought by Ms Sentenenko and any Judgment secured in her favour .
REPLY :
Please find attached document that explains it all. We have since obtained a judgement to set aside
this. This was a tenant that claimed she had moved into a property with a fake tenancy agreement
and claimed she was forcefully evicted and all our possession were thrown away. The Claim was
for damages. The j udgement was entered in our absence. We have applied for the judgement to be
set aside since and have now been granted a judgement.
{ v ) Please iden t i f y the parties to whom rent i s p a i d and provide evidence of the
payment of rent for the last 6 months . Please can you give an account
( a l be i t that may be more general t e rms ) a s to the rental income received
across the property port folio and i t s d i s tribution)
REPL Y :
Rent is paid to DNA and I pay for the expenses and mo1tgages out of it.
Property is occupied by : Ground Floor F lat : Monir Ahmed
First Floor flat : Abdul Quyum
48 Shaftsbury Road
{i) The most recent profe s s i onal va luation you hold for the prope r t y .
Reply :
Please find attached. The Property is currently valued at £504,000

{ii) The most recent redempt ion statement you have for the mortgage held by
Rosol i t e Mortgages Ltd. If that redemption statement i s more than 3
months then please do secure an up to date redemp t i on s tatement .
Reply :
50
(iii) A copy of the charging order held by Elias Hussain dated 6 Jul y 2 0 1 5 .
Reply : Please find attached.

( iv ) P l e a s e identify t h e part i e s t o whom r e n t i s p a i d a n d provide evidence of
( albeit that may be more general terms) as to the rental income received
across the property portfolio and its distribu t i o n }
Reply : The Property is occupied by Mr Abdul Gani and family.

The rent is paid to DNA. P lease see attached rent collection spreadsheet and its distribution.
17 Bristol Road
(i) The most recent profess ional valu a t i on you hold for the propert y .
Reply :
Please find attached. The property is currently valued at £486,000
( i i ) The most recent redemp t i on statement you hold for the mortgage held by
Ken s i ngton Mortgage Company. I f that redemp t i on statement i s more than
3 months old then please do provide a current redemption s t atemen t .
Reply :
( i i i ) The charging orders s e cured by Elias Hussain dated 6July 2 0 1 5 , 9 July

2 0 1 5 , 9 June 2 0 1 6 and 1 8 October 2 0 1 6 .
Reply :

( i v ) P l ea s e i dentify the parties to whom rent i s paid and provide evidence of
( a lbe i t that may be more general terms ) as to the rental income received
across the property portfolio and its dis tribut i o n )
Reply :
The Prope,ty is occupied by : Mr Misbaur Rahman
The rent is paid to DNA. Please see attached rent collection spreadsheet and its distribution.
2 1 4 Plashet Grove
51
(i) A copy of the most recent profess ional valuation you hold for the
prope rty .
Reply :
Please find attached. The Prope1ty i s currently valued £393,000
(ii) The most recent redemp t i on sta tement you hold i n respect of the mortgage
held by Topaz Finance Ltd. If that redemption s t a tement is more than
3 months old then please do secure up to date redemption s tatemen t .
Reply :
(iii) Please ident i fy the persons currently i n occupa t i on o f the prope rty .
Please ident i f y the date o f the commencement of their occupation and
provide a copy of the tenancy agreement regulating their occupation
of the prope r t y . Please identify the part ies t o whom rent i s paid
and provide evidence of the payment of rent for the last 6 months .
Please can you give an account ( a lbe i t that may be more general te rms )
as to the rental income received across the property portfol i o and
its dist ribut ion)
Reply :
The Property is occupied by : Family's Main Home
Rent : No rent is paid
2 Kepal Road
(i) A copy o f the most recent professional valuation you hold for the
prope r t y .
(ii) The most recent redemp t i on s tatement you hold i n respect o f the mortgage
held by Siberite Mortgages L t d .
( i i i ) The charging orders held by E l i a s Hus s a i n secured on 9 June 2 0 1 6 and 1 8

October 2 0 1 6 . T o the extent to wh ich those charging orders have been
made fi nal then please provide a copy of the final charging orde r .
( iv ) Please identify the parties to whom rent is paid and provide evidence
of the payment o f rent for the l a s t 6 months . Please can you give an
52
account ( albeit that may be more general terms ) as to the rental income
received across the property portfolio and i t s d i s t ribution )
REPLY : The Property is occupied by : Mr Safi Khan Mohamed
Rent : The rent is paid to DNA . Please see attached rent collection spreadsheet and its
distribution.
112 Strone Road
31. Please provi de :
(i) The most recent professi onal valuation you hold for the propert y .
Reply:
The property was sold by Elias Husain i n Auction. Please find attached completion statement
1 9 May 202 1 . This property was undersold. Prior to the sale the property was valued between
£445,000 and £450,000. I n the Auction the property was sold for £39 1 ,000. Again,
Mohammaed was prejudiced because of the timing of the sale. Elias Hussain had l isted the
property i n an Auction at the hight of Covid 1 9 pandemic and the Auction was held only on line.
Had it been for a usual auction with physical presence then the property would have been sold
for at least £450,000, leavening the stakeholders out of pocket by at least £60,0000. Elias had
been negligent to the stake holders to an extent as any normal person would have delayed the
sale until at least the pandemic restrictions were relaxed and law allowed people to gather
again and this way the property would have been sold for the correct market price.
(ii) The most recent redempt ion s t a t ement you hold for the mortgage held
by One Savings Ban k . I f that redempt ion s tatement i s more than 3
months old then p l ease do provide a current redemp t i on statemen t .
Reply:
Not Applicable.
( i i i ) Please provide confi rma t i on of the relationship between Ansah Tariq

and the bankrupt and/or Dabir and/or to any of the parties to the deed
of trust dated 28 May 2 0 0 8 o r to any spouse or child of a party t o the
deed of trust dated 28 May 2 0 0 8 .
Reply:
(iv) Not Applicable.
(v) Please ident i f y the persons currently in occupation of the prope r t y .

Please ident i f y the date of the commencement of the i r occupation and
provide a copy of the tenancy agreement regulating the i r occupation
of the prope r t y . Please ide n t i fy t h e parties t o whom rent i s p a i d and
provide evidence of the payment of rent for the l a s t 6 months . Please
can you give an account ( albeit that may be more general t e rms ) as to
the rental income received across the proper t y portfolio and i t s
d i s t r ibution)
Reply:
53
(vi) Not Applicable.
Generally
Please provide a copy of the s t atutory demand presented by Elias Hus s a i n upon
which the bankruptcy p e t i t i on presented by him was premi sed . To the extent
any application was made seeking to set aside that statutory demand then
please provide a copy of that application, any evidence fi led in relat ion to
it and any orders made within the appl ication .
REPLY :

3 2 . Please provide a copy of any app l i cations for final charging orders made
by Mr Hussain together with any evidence fi led within those proceedings and
orders made within them . I t is incumbent upon Mr Hussain to not i f y any
credi tors known to him of h i s appl icat i on . To what extent did other
credi tors of you receive notice of those app l i c a t ions and did they
intervene?
REPLY :
3 3 . Please provide a copy of any written j udgments provided by any Master or

Judge whether i n the bankruptcy proceedi ngs , the Judgment secured by Mr
Hussain or the charging order proceedings . A number of abbreviated
j udgments have been brought to our atten t i on but they are broadly incomplete
both in their fullness and i n relat ion to the totality of the proceedings .
REPLY :

34 . In the Bankruptcy Booklet there is reference to shares being held by
Mohammed Ahme d . Please provide details of these shares and your est imated
of their value .
REPLY :
The Shares were held at Halifax Bank, I Think it was valued around £ 1 ,000 at time. Official
receiver took it all.
3 5 . I n the records provided by the Official Receiver i t i s indicated that there

is outstanding rent owed to the Bankruptcy Estate . Please provide details
of any rent that is outstanding . If there i s no rent outstanding please
explain why .
REPLY :
Please find attached the rent statement. Accordingly there 1s no rent currently due to the
bankruptcy estate.
54
3 6 . Please ident i fy the terms that you propose to offer to credi tors within the
terms of your Individual Voluntary Arrangement and the outcome you wish t o
achieve a s a consequence of a successful Voluntary Arrangement?
REPLY :
We have calculated the value from the net realisation of asset held as Mohammad's beneficial
interest. DNA proposes to put forward a lump sum in accordance with MKA's she of the assets
and help MKA to propose an IVA.
3 7 . I n relat ion to the debts you have iden t i f ied to the Official Receiver, i n
relation to Ani s ah Tariq, Dab i r Ahmed, Hazrat Hussain, Jalal Uddin and
Muhammed Kadir pleas e :
( i) Provide me with such documentary evidence a s you have a s t o each o f

these debts and t h e quantum and value att ributed t o them .
REPLY :
Please find attached documentary evidences in supp011 and the value attributed to them
( i i ) Provide a short written explanation of the c i rcumstances in which those

l i a b i l i t i e s came to be incurred .
REPLY :
A SHORT EXPLNATION OF EACH LOAN I S PROVI DED BELOW :
DABIR LOAN:
Total Lon Amount: £1,72 1 747.59 including any interest
Money was borrowed to purchase 2A Keppel Road for £425,0000 when Mr Hussain had failed
to come with the money. l requested Dabir to meet the shortfall and he had lent the shortfall.
The property needed development where MKA had spent around £319,000 before it was
mo11gaged with Bank of Scotland. It was largely borrowed from Dabir and others.
ln the year 2008 MKA had set up a company called St Martins and the cost of setting up was
approximately £40,0000. This was borrowed from Dabir and other members of the family. In
the Year 20 10, Hussain had left the business but whilst he was in the business he had stollen
Tenants Deposit for the sum of around £29,000. MKA had borrowed from Dabir to meet this
sho11fall.
ln the same year of 2008 another company was set up by MKA with Elias , the cost of this
was borrowed from Dabir. Then there were other cost in between
BUILDING WITHOUT PLANNING PERMISION:
Whilst Mr Hussain had been in occupation of 2A Keppel Road, he had conducted some
building work without planning pennission. In year 20 1 2, London Borough of Newham had
issued enforcement notice and demanded that property be amended as otherwise they \.VOuld
demolish the building at their own cost. Cost of dealing with enforcement including the legal
55
cost for a Public Hearing and subsequently building works had cost around £66,000. This was
borrowed from Dabir.
LITIGATION
Hussain started the I itigation on or around 2010, It had cost MKA a lot of fees in terms of legal
fees. These fees were borrowed from Different people on the creditors list including Dabir. A
full list of cost for all legal cost for this matter is available should you wish to review it.
DAB IR SHARE OF 307 KA THER1NE ROAD AND 1 12 STRONE ROAD
Dabir waved his 95% share in favour of MKA on the promise from Nigel Smith that he would
not seek MKA's bankruptcy. Nigel Smith took the money but still pressed ahead with the
bankruptcy.
For 307 Katherine Road , Dabir gave up his 95% share for the sum of£168,235.49 and loaned
the money to MKA
For 1 1 2 Strone Road, Dabir Loaned MKA 95 % of his share for the sum of £ I 54,911.28 and
loaned the money to MKA.
This was on the promise that if Dabir gave up his share and loaned the money to MKA for
Nigel Smith to take then Mr Smith wouldn't seek MKA's Bankruptcy.
HAZRA T LOAN:
Total Loan Amount : £195,455 including interest.
In the year 2008, borrowed a total of£13,400. This was spent on developing 2A Keppel Road.
In the year 2013, total borrowed was £28, I 35. This was spent on setting up a medical business
that had subsequently failed. Some of the funds were spent in dealing with the Enforcement
notice served on 2A Keppel Road. The enforcement notice was appealed that had lead to a
Public enquiry. There was a total of 6 hearing all together each costing around £4,000 in
ba1Tister fee alone and then the cost of a solicitor too.
Between 20 1 4 AND 201 5, TOTAL BORROWED WAS £13,450 for the business as above
and further funds for the sum of £2 I ,580 was borrowed between 2016 and 20 I 8.
Between 2018 and 2020, total botTowed was £62,500. This was largely spent on , Mortgage
payment due to Bank of Scotland for 2A Keppel Road, in the region of £2,100 per month
from 2008 until he property was sold where Elias failed to contribute his 50% share of the
liability. The 'Hazrat Loan was also used to fund the legal cost for the case of Elias and
Mohammad renovated his house at a cost of around £ 18,000 to £ I 9,000.00
JALAL UDDIN LOAN:
Money borrowed from Mr Uddin was largely spent on dealing with the legal cost. That
included at least half of it spend on dealing with Bankruptcy proceedings. The Stats demand
was issued on 20 Feb 2020. Initially an application was made to set aside the stats demand at
cost of nearly £ I 0,000 in legal fees that involved 2 hearings.
56
Subsequently, there a total of around 6 hearing at cost of nearly £4,000 for each hearing both
in barristers cost and solicitor's cost. There was other cost associated with the whole process.
The cost of obtaining, valuation cost for each property among other cost. The list very
extensive and for the sake of keeping matters brief I have limited the explanation to main core
parts only.
BEGUM SUFIA AHMED LOAN:
Total sums borrowed in the year 2014 were £17,400. A full breakdown is available if you wish
to see it. These were spent on Medical Company. The loan of£14,000 was spent, split between
legal cost and overheads of the medical company. £8200 borrowed in 2016 was spent on
maintaining the overheads. The sums borrowed in 2019 and 2021 almost all of it had been
spent on legal cost.
D R ANISAH TARIQ LOAN
The borrowed between 2017 and 2019 were spent on setting up the Medical Company.
A loan of £ I 43,421 was made to cover debt with banks. He balance was spent mainly on legal
cost fighting the Elias case. A balance of around £ 12500 was spent on renovating 112 Strone
Road.
MOHAMAMED ABDUL KADIR LOAN :
Money borrowed from Mr Kadir between 2020 and 2021 were almost all of it spent on 2A
Keppel Road fixing the roofs etc in anticipation of selling it in the open market to pay off the
debt with Bank of Scotland. In the end Elias went to the Court seeking the conduct of sale be
given to Mr Nigel Smith. Mr Smith was given the conduct of sale on IO Feb 2020 by DJ
Jackson. He then conducted a sham bid on 24 February 2020 and the property on for just
£141,500. The same property was valued £740,000 by Ashdown Lyons ( see attached
valuation by Ashdown Lyons dated 25 Jan 2008) on be half of Bank of Scotland in the year
2008 when it was mortgaged with Bank of Scotland. Even if the property did not go up in
value by a penny in 12 years, it should have been worth at least £740,000 but for some strange
reason Smith had sold the property for just £ 141,000 leaving MKA out of pocket by at least
£599,000/2 = £299,500
( i i i ) Let me have a copy of any j udgment secured by any of those creditors in

relation to their deb t .
As I have mentioned t o you debt due t o assoc i a t ed parties not only have
different vot ing rights but are also the subj ect of closer scrutiny by
dissent ing credi tors or by a Court in the event of a challenge . Indeed
i t is one of the tasks o f the Nominees t o try to be s a t i s fied that there
is substance t o the debt and the values attributed to them . I n those
circumstances therefore, where it i s said, for examp l e , that the debts
arise by loans then do provide documents such as the loan agreements
and evidence of the transfers of money and any repayments e t c .
57
Suite 3 1 6. 3rd Floor
Isadore 70 Gracechurch Street
Goldman
London, EC3V OHR
T 0207 353 l 000
Insolvency & Restructuring F 0207 353 9055
W www.isadoregoldman.com
Dr S Beum
214 Plashet Grove,
East Ham Our ref: KM/TM/PUR001/0081
London, Your ref:
E6 1 DA Date: 14 November 2023
Please ask for: Kevin Mitchell
Email: kmitchell@isadoregoldman.com
Dear Dr Beum,
Re: Mohammad Kamal Ahmed (in Bankruptcy){the "Bankrupt")
We act for Christopher Parkman the Trustee in Bankruptcy of your husband.
As you may be aware, a bankruptcy order was made against the Bankrupt on 24 May 2021 on the
petition of a creditor presented on 30 January 2020. Mr Parkman was appointed to be the Trustee in
Bankruptcy with effect from 1 4 March 2022.
Section 283(A) of the I nsolvency Act 1 986 provides that a Trustee in Bankruptcy is required to take
certain steps to deal with property which is comprised in the estate in bankruptcy of the Bankrupt, and
which was occupied by the Bankrupt and/or his spouse or civil partner, or a former spouse or former
civil partner, within three years from the making of the bankruptcy order.
The period of three years can be extended or disapplied by order of the Court.
From the information provided either to the Insolvency Service or to his Trustee by the Bankrupt, it
would seem that he, and we believe you, were either in occupation of the property at 1 97 Plashet
Grove, E6 1 BX or 2 1 4 Plashet Grove, E6 1 DA as at the date of the bankruptcy order.
The purpose of this letter is to invite your engagement and your confirmation as to the address of the
property at which you resided as at the date of the bankruptcy order namely 24 May 202 1 . We enclose
a stamped addressed envelope to assist you in your reply.
If you would prefer to respond by email, and that would be helpful, then could you please reply to the
following address:
kmitchell@isadoregoldman.com
copying in tmorant@isadoregoldman.com and iklein@isadoregoldman.com
We should make clear that the provisions of section 283(A) of the Insolvency Act 1 986 may not apply in
the case of your husband's bankruptcy on the premise that according to him, the title to the properties at
1 97 and 2 1 4 were not property within his bankruptcy estate but were otherwise regulated by reference
to a deed of trust made on 28 May 2008. That is a matter that is currently under investigation.
However, to ensure that there is no misunderstanding between the parties, it would be helpful if you
could assist by confirming your address as at the relevant date.
Yours faithfully,
London East Anglia South of England

020 7353 1 000 0 1 603 61 l 370 023 9229 2533
Isadore Goldman Insolvency & Restructuring is a trading name or Isadore Gol dman Limited. Alt services ore provided subjecl to our standard terms and conditi ons
of business which are cvci lable a l www.isadoregoldmon. com. Authorised end regulated by the Solicilors Regul ation Authority !SRA No 598736).
Company Number 8377344 Registered office: Suite 316. 3rd floor, 70 Gracechurch Street, London, EC3V OHR. Regi stered in Engl and and Wal es
58
Isadore
Goldman
Isadore Goldman
59
Isadore Suite 3 1 6, 3rd Floor
70 Gracechurch Street
Goldman London, EC3V OHR

T 0207 353 l 000
Insolvency & Restructuring F 0207 353 9055
Our ref: KM/IK/PUR00l/0081

Your ref:
Dr S Beum Date: 1 9 December 2023
214 Plashet Grove, Please ask for: Kevin Mitchell
East Ham Email: kmitchell@isadoregoldman.com
London,
E6 1 DA
Dear Dr Beum,
Re: Mohammad Kamal Ahmed (in Bankruptcy) (the "Bankrupt")
I refer to my letters to you of 4 December 2023 and 14 November 2023 a copy of which I enclose
for information and to which I have yet to receive the courtesy of a reply.
Would you please ensure that you do reply by no later than 4.00pm 29 December 2023.
In view of potential delays in postage, might I invite you to respond by email.
My email address is: kmitchell@isadoregoldman.com
Would you mind also copying any email you send to me to my colleagues:
iklien@isadoregoldman.com
tmorant@isadoregoldman.com
I look forward to hearing from you.
Yours sincerely,
Kevin Mitchell
London East Anglia South of England

020 7353 1 000 0 1 603 6 1 1 370 023 9229 2533
Isadore Goldman Insolvency & Reslructuring is a trading name of Isadore Gol dman Limiled. An services ore provided su!:>ject to our stondcrd terms end conditions
of O\Jsiness which ere ovoil cOle at www.isadoregoldmon.com. Authorised and regul ated by the Solicitors Regulation Authority !SRA No 598736).
Company Number 837i3.!4 Regi stered office: Suite 316. 3rd Floor, 70 Grocechurch Street. London, EC3V OHR. Registered in Engl and and Wal es
60
From: Kevin Mitchell
To: Kamal Ahmed
Cc: Kevin Mitchell; Isabelle Klein; Terri Morant
Subject: Ref Isadore Goldman Limited:MA:PUR00l/0081
Date: 14 November 2023 15: 18:00
Dear Mr Ahmed
Your estate in Bankruptcy
As you are aware, a bankruptcy order was made against you on 24 May 2021 on the petition of a
creditor presented on 30 January 2020. My client, Christopher Parkman was appointed to be your
Trustee in Bankruptcy with effect from 14 March 2022.
Section 283(A) of the Insolvency Act 1986 requires your Trustee to take certain steps to realise his
interest in any property which was comprised in your estate in bankruptcy at the time of the
making of the order, and which was occupied by you and/or your wife, and/or any former wife,
within three years from the date of the bankruptcy order.
Based upon the information you have provided to the Insolvency Service and/or to your Trustee in
Bankruptcy, it would seem that as at the date of the bankruptcy order, it was either the property
at 197 Plashet Grove, London E6 lBX or that at 214 Plashet Grove, London E6 lDA that was
occupied by you and/or your wife as at the date of the bankru ptcy order.
I would be grateful for your confirmation that you and your wife ( and/ or any ex-wife) were only
in occupation of either of these properties as at the date of the bankruptcy order. If you a nd/or
your wife ( or any former wife) were in occupation of any other property as at the date of the
bankruptcy order, then would you please provide a note of the address of that property.
As I have mentioned above, it is only property which comprises an asset in your estate in
ban kruptcy at the time of the bankru ptcy order which enjoys the benefit of the provisions of
section 283(A). As you know it has been asserted by you, that the title to 197 and 214 was in
fact regulated by reference to a Deed of Trust dated 28 May 2008 and as such neither property
at that date comprised an asset in the estate.
I do however require clear confirmation as to the addresses occupied by you and/or your wife as
at the date of the ban kruptcy order and I would remind you that you remain under a statutory
obligation to assist my client pursuant to the provisions of section 333 of the Insolvency Act
1986.
I look forward to hearing from you.
Yours sincerely,
Kevin Mitchell
61
62
63
64
65
Suite 316, 3rd Floor
70 Gracechurch Street
London
EC3V 0HR
T 023 9229 2533
High Court of Justice Our ref: MK/IK/PUR001/81

Business and Property Courts,
Your ref: BR-2020-000102
7 Rolls Buildings,
Fetter Lane, Date: 14 March 2024
London
Please ask for: Monica Kapur
EC4A 1NL
Kevin Mitchell
By Ce-file
Isabelle Klein
Email: mkapur@isadoregoldman.com
Dear Sirs kmitchell@isadoregoldman.com
iklein@isadoregoldman.com
Mohammad Kamal Ahmed in Bankruptcy
Our client: Christopher William Parkman, the Trustee in Bankruptcy
Hearing:4 April 2024,10:30am,
Case Number – BR 2020-00102
We act on behalf of Christopher William Parkman, the Trustee in Bankruptcy of Mohammed Kamal Ahmed.
We refer to the hearing of our client’s application on 4 April 2024. We have served the Respondents with our
client’s Application and enclose for filing the following:
1. Certificate of Service for Mohammad Kamal Ahmed dated 14 March 2024; and
2. Certificate of service for Sufia Beum dated 14 March 2023
We would be grateful if the same could be placed on the court file ahead of the hearing. If you have any
queries, please contact Isabelle Klein on 07596 566522.
Yours faithfully
ISADORE GOLDMAN
London East Anglia South of

020 7353 1000 01603 611 370 England
023 9229 2533
Isadore Goldman Insolvency & Restructuring is a trading name of Isadore Goldman Limited. All services are provided subject to our standard terms and conditions
of business which are available at www.isadoregoldman.com. Authorised and regulated by the Solicitors Regulation Authority (SRA No 598736).
Company Number 8377344 Registered office: Suite 203, 2nd Floor, 70 Gracechurch Street, London, EC3V 0HR. Registered in England and Wales
66
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Case No: BR- 2020- 000102

IN THE HIGH COURT OF JUSTICE BUSINESS AND

CHRISTOPHER WILLIAM PARKMAN

(1) MOHAMMAD KAMAL AHMED

(2) SUFIA BEUM

INDEX TO BUNDLE FOR HEARING ON 4 APRIL 2024 AT 10:30AM

TAB DOCUMENT PAGES

1 Application Notice dated 23 February 2024 3-5

2 Draft Order 6-8

3 Witness Statement of Christopher William Parkman dated 23 February 2024 9 - 13

4 Exhibit CWP1 dated 23 February 2024 14 - 61

5 Certificate of service for Sufia Beum dated 14 March 2024 62 - 63

6 Certificate of service for Mohammad Kamal Ahmed dated 14 March 2024 64 - 65

See Form IAA-N for

Insert name of BETWEEN

IAA - Insolvency Act Application Notice (04.17)

IN THE HIGH COURT OF JUSTICE BUSINESS AND

CHRISTOPHER WILLIAM PARKMAN

(1) MOHAMMED KAMAL AHMED First Respondent

(2) SUFIA BEUM

UPON the Applicant’s application dated 23 February 2024

1.1 197 Plashet Grove, London E6 1BX

2. Costs of the Application

Dated this day of February 2024

Service of this Order

IN THE HIGH COURT OF JUSTICE

BEFORE [NAME OF REGISTRAR OR

CHRISTOPHER WILLIAM PARKMAN

(1) MOHAMMAD KAMAL AHMED

IN THE HIGH COURT OF JUSTICE BUSINESS AND

CHRISTOPHER WILLIAM PARKMAN

(1) MOHAMMAD KAMAL AHMED

South Benfleet, Essex, SS7 SHA and

Benfleet, Essex, SS7 SHA and

NOW THJS DEED WlTNESSETH as follows:

such time this agreement is ratified/ amended or superseded by a subsequent

agreement; agreed upon by all parties concerned.

individual sole ownership or partnership._

Property from time to time

relating to the sale and any estate agents' commission

property is owned or operated ,vithin a limited company.

representative of the deceased party's estate jointly if applicable) or if no agreement

can be reached to be appointed by the President of the Royal Institute of Chartered

have the corresponding meaning.

be ascertained by a Redemption Statement from the Lender dated within 28 days.

be the director a company under which the property is held.

of the Property including the Mortgage re-payments.

themselves in the following shares:

3.1. I As to the % shares absolutely described in SCHEDULE ONE for Kamal,

Kabir, Dabir, Sufia. Afia and Hazrat.

to compliance with all statutory requirements and by laws which may be in

force from time to time;

contribute towards those payments

mortgages are obtained under these 2 names only.

3.3 The parties hereto further agree that:

as set out in sub clause 3.3.1.1 hereof;

purchase the Property by way of payment to the Executors or Personal

of Probate or Grant of Representation, whichever is the later, unless a longer period is

agreed by the said Executors or Personal Representatives