Ms Sandra Messi

Case Summary

The Attorney General applied for a restriction of proceedings order against Ms Sandra Messi under section 33 of the Employment Tribunals Act 1996, on the basis that she is a vexatious litigant. The Employment Appeal Tribunal reviewed Ms Messi's extensive litigation history and determined that the test for a restriction order was satisfied.

The Employment Appeal Tribunal found that Ms Messi satisfied the test for a restriction of proceedings order under section 33 of the Employment Tribunals Act 1996, based on her extensive litigation history demonstrating vexatious conduct.

• •vexatious litigation
• •abuse of process

Judgment approved by the court for handing down The Attorney General v Ms Sandra Messi © EAT 2026 Page 1 [2026] EAT 34 Neutral Citation Number: [2026] EAT 34 Case No: EA-2025-000003-RN EMPLOYMENT APPEAL TRIBUNAL Rolls Building Fetter Lane, London, EC4A 1NL Date: 03 March 2026 Before: THE HONOURABLE MR JUSTICE SHELDON MISS EMMA LENEHAN MR NICK AZIZ - - - - - - - - - - - - - - - - - - - - - Between: THE ATTORNEY GENERAL Applicant - and – MS SANDRA MESSI Respondent - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Richard Boyle (instructed by Government Legal Department) for the Applicant The Respondent represented herself, but made no oral representations Hearing date: 18 th December 2025 - - - - - - - - - - - - - - - - - - - - - JUDGMENT Judgment approved by the court for handing down The Attorney General v Ms Sandra Messi © EAT 2026 Page 2 [2026] EAT 34 SUMMARY Practice and Procedure His Majesty’s Attorney General applied for a restriction of proceedings order against Ms Sandra Messi under section 33 of the Employment Tribunals Act 1996 (“the ETA”), on the basis that she is a vexatious litigant. Section 33 of the ETA permits the Employment Appeal Tribunal (EAT) to impose a restriction order where a person has habitually and persistently and without reasonable ground instituted vexatious proceedings or made vexatious applications. The EAT reviewed extensive materials evidencing Ms Messi’s …