Latter Rain Outpouring Project v Green: High Court refuses interim injunctions in church company control dispute

The High Court has refused to grant a raft of interim injunctions sought by a church-linked company locked in a bitter dispute over its governance and property, ordering instead a preliminary issue trial to establish who the company's members lawfully are. The judgement in Latter Rain Outpouring Project Limited v Creswell Lindsay Green & Ors [2026] EWHC 1381 (Ch), handed down by Adam Kramer KC sitting as a High Court judge on 9 June 2026, exposes the limitations of interim relief in company control disputes where authority to bring proceedings is itself in question.

Latter Rain Outpouring Project Limited is a company limited by guarantee that owns a property at 234-242A Hoxton Street, London, used partly as a church and partly let as a flat and four shops, with a value said to exceed £3 million. A schism within the associated Pentecostal church has produced two competing factions: a Hoxton congregation, which initiated proceedings in the company's name, and a Peckham congregation supporting the first respondent, Bishop Creswell Green, who was at all material times both the church's bishop and, under article 4.4 of the company's articles, an ex officio director by virtue of holding that office.

The Hoxton faction contended that an extraordinary general meeting held on 11 July 2025 had validly removed the three respondents as directors and appointed replacements. The respondents denied this. The company sought declarations confirming the removal, rectification of the Companies House register, injunctions preventing the respondents from acting on the company's behalf, and orders relating to a bridging loan of approximately £260,000 secured on the Property in August 2025 by charges granted by the respondents purportedly as directors.

The court identified multiple obstacles to the relief sought. On the EGM, several procedural irregularities arose: the meeting was called by five members rather than the directors, without following the section 303 or section 305 Companies Act 2006 procedure; notice was given by email rather than personal delivery or pre-paid post as required by the articles; and the 21 days' notice given fell short of the 28-day special notice requirement under section 312 for resolutions to remove directors. Whilst some procedural defects can be cured if the will of the majority is known, that question could not be answered here because the composition of the membership was itself fundamentally in dispute.

The deeper issue was article 12.3, which provides that membership is automatic for members of the "Latter-Rain Outpouring International Ministries." The Hoxton faction interpreted that as the Hoxton congregation alone. The respondents contended it encompassed the Peckham congregation too. A separate company with that precise name, number 13900729, was incorporated in February 2022, the same time as the current articles were registered, lending some support to the respondents' position. Resolution of that question was, the court found, not possible on the evidence available at an interim hearing.

Adam Kramer KC declined to grant the declarations sought, characterising them as final rather than interim in nature. Applying the principles in Lenovo Group Ltd v Interdigital Technology Corporation [2024] EWHC 596 (Ch), he held that declarations which take a side on a substantive question of law cannot properly be granted as interim relief, and that the merits did not so clearly favour the applicant as to permit a summary determination.

On the Charles Street charges, the court found it could not grant relief without joining Charles Street as a respondent, noting that the lender had not been notified of the application and had obvious arguments on apparent authority and unjust enrichment. The application for return of £150,000 paid to a construction company failed for equivalent reasons, the payee not being before the court.

The court ordered that the claim form be issued and served forthwith, directed a preliminary issue trial on membership and directorship, and accepted the respondents' offer to continue the undertakings from the earlier Mann J order pending that resolution. Costs were reserved to the preliminary issue judge.

Latter Rain Outpouring Project Limited v Creswell Lindsay Green & Ors [2026] EWHC 1381 (Ch). Horaine Henry (direct access) for the applicant; Duncan Kynoch (direct access) for the respondents.