Original in-game verdict

Background 1. Willowglass Repairs Ltd asks the Court to set aside an employer preparation circular only insofar as it directs employers to change existing right-to-work checks. The defendant is Eleanor Whitcombe, Secretary of State for the Home Department. The dispute concerns the meaning and effect of the circular, not a claim for money. 2. The record includes the circular and a ministerial announcement dated 25 October 2026. The announcement describes renewed debate and examination of negotiating options and announces no agreement or new immigration entitlement. The circular says employers “should prepare to accept participating European applicants without sponsorship,” and also says existing right-to-work checks remain in place pending further notice. Issues for determination 3. The issues are whether the circular directs employers to change current checks; whether the Secretary’s position has support in the record; and whether Willowglass has proved a basis for its requested narrow remedy. Under Rule 1, Willowglass bears the burden of supporting the relief it seeks with specific evidence. Under Rule 45, the agency’s position must have support in the record. Rule 6 requires a remedy to match the harm established. Submissions of the parties 4. Willowglass argues that “should prepare to accept” is a present instruction to employers to change their practices, despite the announcement creating no new immigration entitlement. It accepts that the circular did not expressly cancel current checks and that it has no separate evidence of actual changes or of an additional instruction in practice. It asks only that the circular be set aside to the extent it directs a change to existing checks. 5. The Secretary argues that the circular preserves current checks and does not change immigration rights or instruct employers to dispense with sponsorship. The Secretary relies on the circular and the announcement, and says the circular asks employers to plan for a possibility. The Secretary’s client account acknowledges that the wording could have been clearer and that practical application would require investigation. Evidence and findings 6. The circular is presented in several copies, including exhibits 3-e2, 4-e2, 7-e2, and 9-e2. The copies contain the same two relevant statements. Their authenticity is not materially disputed; the dispute is about meaning. The circular is direct and reliable evidence of what it says, but its two statements pull in different directions: preparation for acceptance without sponsorship on one hand, and preservation of existing checks on the other. 7. The announcement, exhibits 4-e1 and 9-e1, is good evidence of what was announced. It records debate and examination of options, not a new entitlement. It does not, by itself, establish every later administrative act or explain how employers were expected to apply the circular. 8. Willowglass’s submissions are arguments, not independent proof of practical effect. Its final statement expressly says it has no separate evidence that employers changed checks or were told to do so in practice. The Secretary’s client statements are attributed accounts relayed by counsel, not independent agency records or admitted witness testimony. They support the Secretary’s explanation as an account, but carry less weight than a contemporaneous agency record would. No such separate record is identified. Reasons 9. On the first issue, Willowglass has not proved that the circular directs a change to current checks. The phrase “should prepare to accept” is addressed to employers and reasonably gives rise to uncertainty about what preparation entails. But the circular’s final paragraph expressly says existing checks remain in place pending further notice. Willowglass accepts that this means the circular did not expressly cancel current checks. There is no evidence of actual changes, a separate instruction, or other practical application that resolves the ambiguity in Willowglass’s favor. 10. The Court does not treat the absence of proof of actual changes as proof that the circular could never affect employer behavior. It means only that the record does not establish the particular present direction on which Willowglass’s requested order depends. Applying Rule 1 and the reliable-records principle in Rule 2, the text supports concern but does not carry Willowglass’s burden to establish that employers were directed to change current checks now. This issue is not proven. 11. On the second issue, the Secretary has shown record support for the narrower position that current checks remained in place and that no new immigration entitlement was announced. The circular itself expressly preserves existing checks, and the announcement confirms the absence of a new entitlement. The Secretary has not established, through a separate agency record, how the circular was intended to operate in practice. That limitation prevents the Court from treating the Secretary’s broader explanation as independently verified. It does not, however, displace the direct documentary support for the limited position relevant to the claim. This issue is established to that extent. 12. On the third issue, Willowglass’s requested remedy is carefully limited, but narrowness alone does not establish entitlement to relief. Rule 6 requires a remedy to correspond to a proven harm or direction. Because Willowglass has not proved that the circular directs a change to existing checks, there is no established part of the circular that can be set aside on the terms requested. The remedy issue is not proven. 13. The Court has considered the Secretary’s failure to identify a separate practical-application record. That gap leaves uncertainty about how the circular might be understood or used in practice. It does not shift Willowglass’s burden to prove the factual basis for its requested relief, nor does it justify an order based on a possible effect that the available evidence does not establish. No further obtainable proof has been identified, and the matter is decided on the record presented. Final order 14. Willowglass Repairs Ltd’s request to set aside the circular insofar as it directs employers to change existing right-to-work checks is denied. No monetary award is made. The Secretary of State for the Home Department prevails. This order decides only the claim and evidence presented; it does not determine the effect of any later notice, new entitlement, or proven practical application not in this record.