Wonop ApS v FAI Realisations 2024 Ltd: when paragraph 84 ends an administration

In Wonop ApS v Simon Jagger & Ors (Re FAI Realisations 2024 Ltd) [2026] EWHC 362 (Ch), Chief Insolvency and Companies Court Judge Briggs considered whether the registration of a paragraph 84 notice at Companies House operated to end an administration automatically, notwithstanding prior court orders appointing replacement administrators and extending the administration's term.

FAI Realisations 2024 Limited, the UK administrative arm of the Fetch.ai cryptocurrency and blockchain platform, entered administration in January 2024. The applicant, Wonop ApS, was a creditor by virtue of an order obtained in November 2023 for unpaid FET tokens valued at approximately US$746,000. Dissatisfied with a pre-pack sale of the company's assets to an entity associated with the founder — and with the conduct of the joint administrators more broadly — Wonop applied in January 2026 for their removal without discharge and their replacement with new officeholders.

The procedural sequence gave rise to the central question. On 20 January 2026, whilst the removal application was pending, the joint administrators filed a notice at Companies House under paragraph 84 of Schedule B1 to the Insolvency Act 1986, signalling their intention to move from administration to dissolution on the basis that the company had no assets capable of distribution. On 21 January, Rajah J granted interim relief appointing replacement administrators — Andrew Duncan and Steven Illes of Macintyre Hudson LLP — and extending the administration to 19 March 2026. Companies House registered the paragraph 84 notice on 26 January 2026. The question for Judge Briggs was stark: did registration on that date bring the administration to an end by operation of paragraph 84(4), regardless of what Rajah J had ordered five days earlier?

Counsel for the applicant argued that Parliament could not have intended paragraph 84(4) to operate so as to circumvent a court order replacing administrators, and that construing the provision in that way would produce an absurd result inconsistent with the replacement jurisdiction under paragraph 95. He further contended that the joint administrators lacked standing to file the notice in the first place.

Judge Briggs rejected both arguments. On standing, the filing occurred whilst the joint administrators remained in office, and standing was accordingly not in issue. On the interpretive question, he applied the purposive approach confirmed in R (O) v Secretary of State for the Home Department [2022] UKSC 3 and as recently restated by Miles LJ in Cadent Gas Limited v City Fibre Limited [2026] EWCA Civ 46. Drawing on the Explanatory Notes to the Enterprise Act 2002 and the Court of Appeal's reasoning in Re Globespan Airways Ltd [2013] 1 WLR 1122 — which concerned the analogous paragraph 83 exit route — he held that paragraph 84(4) operates as a self-executing termination of the administrator's appointment upon registration. The checking process performed by the Registrar between filing and registration, and the short period that process typically takes, were deliberate features of the legislative scheme, not incidental ones.

The distinction between paragraphs 84 and 95 did not assist the applicant. Paragraph 95 presupposes the continued existence of the office of administrator and concerns only who holds it; it cannot preserve an office that has already been extinguished by paragraph 84(4). Rajah J had not been addressed on the notice or its legal effect, and there was accordingly no basis for treating his orders as having disapplied paragraph 84.

The judgement confirms that the paragraph 84 exit is self-contained and, once registered, absolute. Where dissolution is the chosen exit route, the administration ends by statute on registration regardless of intervening court orders — a conclusion that underscores the importance of applicants monitoring Companies House filings closely when removal proceedings are on foot.

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