UK Court of Appeal rejects Letter One’s appeal on compensation under A1P1 of the ECHR in National Security & Investment Act case

3 December 2025

The Court of Appeal has given judgment in L1T FM Holdings Ltd & Anor, R (On the Application Of) v Chancellor of the Duchy of Lancaster in the Cabinet Office [2025] EWCA Civ 1528.

Among the ultimate beneficial owners of Letter One are Mikhail Fridman, Petr Aven, and German Khan, whom the UK sanctioned in 2022. Letter One bought Upp, a broadband company, in 2021. The UK Government used its powers under the National Security and Investment Act to order Letter One to divest its shareholding in Upp in 2022 because it said Letter One’s sanctioned owners created a risk to national security. Letter One sold Upp in 2023 at a rate it said was below market price because its sale was forced by the government.

L1T sought judicial review of the NSIA order on several grounds in the High Court, all of which were rejected – see previous coverage. Letter One was granted permission to appeal on one ground – that the High Court was wrong to hold that Article 1 of the First Protocol to the European Convention on Human Rights did not require it to be compensated for deprivation of its possessions beyond what it obtained from the sale of Upp which was compelled by the Government.

The Court of Appeal rejected the appeal and declined to make a declaration that Letter One was entitled to compensation under A1P1.  The court cited Shvidler and the government’s wide margin of judgment to determine whether a measure is proportionate in a national security context.