Jurisdiction(s):
United Kingdom

Restructuring plans: invalidity of one-person class meetings and scope of retail advocate submissions—English High Court in Re Argo Blockchain Plc

Published on: 11 February 2026

Published by a LexisNexis Restructuring & Insolvency expert

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Article summary

Argo Blockchain Plc, Re [2025] EWHC 3395 (Ch)

What are the practical implications of this case?

First, the ruling delineates the proper approach to class meetings within restructuring plan proceedings. In 2024, the Scottish Outer House of the Court of Session determined that a class meeting could be valid with only a single attendee, provided that attendee held sufficient proxies to make the meeting quorate on the footing that each proxy was treated as a person present (see Re Dobbies Garden Centres Ltd [2024] CSOH 111). Mr Justice Hildyard rejected that position, concluding that where a class contains more than one creditor, no valid meeting can occur unless at least two persons are in attendance. The judgment also includes helpful observations on how the court’s approach may require adjustment when turnout at class meetings is low and participation is notably limited. Secondly, the court offered a useful analysis of the remit of an independent advocate and the extent to which that individual should be permitted to criticise the proposed plan on behalf of retail creditors...

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