Insolvency – Voluntary arrangement. The second claimant, P, and his wife, entered into individual voluntary agreements (IVAs) with creditors. P sought a declaration that the IVAs were a nullity. He submitted that he had not expressly consented to modification made to the IVAs, and that the proxy of the Revenue and Customs Commissioners had been used in favour of the modification without authority. The Chancery Division held that, on the evidence, the claim would be dismissed.