Practice – Civil litigation. The defendant Secretary of State sought the dismissal of the claimant's claim for judicial review on the basis of his failure to comply with a consent order, requiring the dismissal of the claim, if he failed to file amended grounds within 21 days. The claimant sought relief from sanctions and explained his failure to comply as due to his lack of funds. The Administrative Court held that the present was not an appropriate case for relief from sanctions and refused the claimant's application. It followed, applying the consent order, that the application for judicial review was to be dismissed.