Council Found in Contempt of Court After Failing to Complete Housing Disrepair Works Ordered by the Court

Housing Disrepair Case Study – Local Authority Landlord Found in Contempt of Court

A local authority landlord has been found in contempt of court after failing to complete repair works required by a court order in a housing disrepair claim.

In Ketrena Francis-Stokes v London Borough of Lambeth, His Honour Judge (HHJ) Hellman, sitting in the Mayor’s and City County Court on 2 July 2026, found that Lambeth had breached an injunction order requiring it to complete repair works at Ms Francis-Stokes’ home. The court found that Lambeth was in contempt of court, even though the works had eventually been completed by the time of the final contempt hearing.

This is an important decision for tenants, landlords, housing associations, local authorities, managing agents, and housing disrepair practitioners. It demonstrates that a landlord cannot safely ignore or repeatedly miss deadlines contained in a court order, then expect to avoid a contempt finding simply because the repairs are eventually carried out before the final hearing.

The case also highlights a wider practical point. In housing disrepair claims, orders requiring works are not merely administrative directions or aspirational targets. They are court orders. If a landlord is ordered to complete specific works by a particular date and fails to do so, the consequences can be serious.

Background To the Housing Disrepair Claim

Ms Ketrena Francis-Stokes had brought housing disrepair proceedings against the London Borough of Lambeth arising from persistent damp and mould at her home. Key aspects of the case include:

• The original claim settled in May 2023.
• As part of that settlement, the London Borough of Lambeth agreed to carry out remedial works by 14 September 2023.
• Those works were not completed within the agreed period.

As a result, Ms Francis-Stokes was forced to issue further court proceedings, under Part 8 of the Civil Procedure Rules, seeking an injunction requiring Lambeth to carry out the works it had already agreed to complete.

On 20 December 2023, Deputy District Judge Greenidge made an injunction order requiring Lambeth to carry out specified repair works within 90 days of service of the order. The order was served on 4 January 2024.

The required works were not completed within the time allowed by the injunction order.

Ms Francis-Stokes therefore applied on 3 October 2024 for Lambeth to be found in contempt of court for breach of the injunction order.

What Is Contempt of Court in a Housing Disrepair Claim?

Contempt of court is a serious matter. In simple terms, it can arise where a party knowingly fails to comply with a clear court order. In the context of housing disrepair, this may happen where a landlord is ordered to complete specific repair works by a certain date and fails to do so.

Court orders requiring works are often made after a landlord has already had a lengthy opportunity to investigate and carry out repairs. A landlord may have received complaints from the tenant, a letter of claim, expert evidence, settlement proposals, and then formal court proceedings. By the time an injunction is granted, the landlord is usually in no doubt about what must be done and when.

Where an injunction order contains a penal notice, the position is even clearer. A penal notice warns the party bound by the order that failure to comply may result in committal proceedings or other serious sanctions. The purpose is to ensure that the person or organisation subject to the order understands that compliance is mandatory.

In a housing disrepair case, contempt proceedings are not the ordinary route. Most claims resolve by agreement, by the completion of repairs, or by a court making orders for compensation and works. However, where a landlord has repeatedly failed to do what it has agreed or been ordered to do, contempt proceedings may become necessary to enforce compliance and uphold the authority of the court.

The Contempt Application Against Lambeth

The contempt application came before HHJ Hellman on several occasions. The court gave Lambeth further opportunities to complete the remaining works. At earlier hearings, the court allowed further time for outstanding items to be done, including the installation of an extractor fan and the replacement of affected plasterwork.

Despite this, further deadlines were missed. By the fourth and final hearing on 2 July 2026, the outstanding repairs had been completed. Lambeth therefore argued, in effect, that because compliance had eventually been achieved, the contempt application should not result in a finding of contempt.

Ms Francis-Stokes pursued the application. Her position was that eventual compliance did not erase the earlier breaches. She had been required to return to court repeatedly, and the works had only been completed after sustained pressure through enforcement and contempt proceedings.

The court accepted that the works had eventually been completed, but that did not end the matter. The question for the court was whether Lambeth had breached clear orders of the court and whether the legal test for contempt was met.

The Legal Test Considered by The Court

The court was taken to authorities on contempt, including R (Bempoa) v Southwark LBC [2002] EWHC 153 and Buzzard-Quashie v Chief Constable of Northamptonshire Police [2025] EWCA Civ 1397.

Relying on the approach in Buzzard-Quashie, counsel for Ms Francis-Stokes submitted that the court should consider three questions:

1. Whether Lambeth failed to do what the orders required.
2. Whether Lambeth intentionally engaged in the conduct constituting the breach.
3. Whether Lambeth knew that such conduct would amount to a breach of an order of the court.

The court reminded itself that contempt must be proved to the criminal standard. That is a high standard. It means the court must be sure that the relevant elements of contempt have been established.

What The Court Found

HHJ Hellman found that Lambeth had repeatedly failed to carry out the works required by the order made by DDJ Greenidge, as later varied by HHJ Hellman.

The court accepted that the delays were partly attributable to factors including resource pressures, staffing difficulties, organisational issues, and disputes relating to access and the timing of works.

However, that was not enough to avoid a finding of contempt. The court concluded that a significant contributing factor was Lambeth’s decision, in circumstances of limited resources, to prioritise other repairs over the repairs required to Ms Francis-Stokes’ home.

That finding was important. The court was satisfied beyond reasonable doubt that this amounted to the necessary intentional element for contempt. The court also found that the orders were clear and unambiguous. Lambeth knew what works were required. It knew the dates by which those works had to be completed. It therefore knew that failure to comply within the required periods would constitute a breach of a court order.

HHJ Hellman was satisfied that the elements of contempt had been established. Lambeth was found to be in contempt of court.

Eventual Completion of Works Did Not Prevent a Contempt Finding

One of the most important points in this case is that the works had been completed by the time of the final hearing.

That did not prevent the court from making a finding of contempt. This is significant because landlords may sometimes assume that if they complete the repairs before the final hearing, the court will treat the matter as resolved. That may happen in some cases, particularly where the breach is minor, promptly remedied, or adequately explained. But this case shows that eventual compliance is not always enough.

Where there has been repeated non-compliance, missed deadlines, and disregard of clear court orders, the court may still consider it necessary to make a contempt finding. The purpose is not simply to secure the works. It is also to uphold the authority of the court.

The court found that a finding of contempt, together with publication of a neutral summary on Lambeth’s website, was a sufficient sanction. No further penalty was imposed.

The Sanction Imposed

The court granted Ms Francis-Stokes’ contempt application.

The court ordered Lambeth to pay Ms Francis-Stokes’ costs of the contempt proceedings on the standard basis, to be assessed if not agreed. Lambeth was ordered to make a payment of £5,000 on account of costs by 3 August 2026.

The court also ordered Lambeth to publish a summary of the judgment in a prominent location on its website by no later than 3 August 2026.

The requirement to publish the judgment summary is particularly noteworthy. It reflects the public interest in transparency where a public authority has been found in contempt of court. It also provides a public record of the court’s finding, while avoiding unnecessary publication of private personal details.

The Wider Cost of Failing to Deal with Disrepair Properly

One of the important wider lessons from this case is that delay in housing disrepair cases is costly for everyone.

This was not a case where a tenant issued proceedings immediately or where the landlord had no opportunity to put matters right. The original disrepair claim began in November 2021. The claim settled in May 2023, with Lambeth agreeing to carry out remedial works by September 2023. When those works were not completed, Ms Francis-Stokes had to issue Part 8 proceedings for an injunction. When the injunction was not complied with, she then had to issue contempt proceedings.

By the time of the final contempt hearing, the financial consequences were already substantial. Lambeth had previously paid costs of more than £9,400 excluding VAT, together with disbursements of more than £10,600. It had also been ordered to pay indemnity costs of £14,416.68 inclusive of VAT for the contempt proceedings up to and including the 10 April 2026 hearing. At the final hearing, the court ordered Lambeth to pay the costs of the contempt proceedings on the standard basis, to be assessed if not agreed, and to make a further payment on account of costs of £5,000.

Those figures matter because they show that poor handling of housing disrepair is not only unfair to tenants. It is also financially inefficient.

Where a landlord is a private landlord, the cost falls on the landlord. Where the landlord is a housing association, the cost ultimately affects the organisation’s resources. Where the landlord is a local authority, the position is even more sensitive because avoidable legal costs are paid from public funds. That means the cost of failing to complete repairs properly and on time can ultimately fall on the same public purse that funds other council services.

This is why housing disrepair should be treated as an operational, legal, financial, and reputational risk. A landlord that fails to act promptly may end up paying for the repairs, the tenant’s compensation, its own legal representation, the tenant’s legal costs, expert fees, court fees, enforcement costs, and contempt proceedings. In many cases, early repair works would have been much cheaper than years of litigation.

The point is not simply that landlords should avoid being sued. The point is that tenants should not have to litigate repeatedly to secure basic repairs, and public bodies should not allow avoidable litigation costs to accrue when timely compliance would protect both the tenant and the taxpayer.

Why This Case Matters for Tenants

For tenants, this case is a clear reminder that there are enforcement options where a landlord agrees or is ordered to complete works but fails to do so.

Many tenants assume that once a housing disrepair claim settles, the matter is finished. In many cases, it is. The landlord pays compensation, completes the repairs, and the claim concludes. However, problems arise where the landlord agrees to carry out works and then fails to do so, or where a court order requiring works is ignored.

In those circumstances, tenants may be able to take further enforcement action. Depending on the wording of the order and the facts of the case, that may include applying for further directions, seeking an injunction, applying to enforce an existing injunction, or bringing contempt proceedings.

Tenants should not ignore non-compliance. If a landlord misses a deadline in a settlement agreement or court order, the tenant should keep careful records. This should include photographs, videos, correspondence, appointment dates, missed appointments, and details of any continuing impact on the household.

A tenant should also be careful not to obstruct access. If a landlord is trying to complete court-ordered works, the tenant should cooperate with reasonable appointments and keep a clear record of their availability. Allegations about access are common in housing disrepair litigation, so written evidence is important.

Why This Case Matters for Landlords and Local Authorities

For landlords, housing associations, local authorities, and managing agents, the lesson is straightforward: if the court orders works to be done, those works must be treated as a priority.

Resource pressures, staffing difficulties, contractor issues, and internal administrative problems may explain delay, but they will not necessarily excuse breach of a court order. Once a landlord is subject to an injunction, the matter needs senior oversight and clear operational control.

A landlord should know:

1. What works have been ordered.
2. The precise deadline for each item of work.
3. Who is responsible for arranging the works.
4. Whether access has been requested and confirmed.
5. Whether contractors have been instructed properly.
6. Whether completion evidence has been obtained.
7. Whether the tenant has been kept informed.
8. Whether the court needs to be updated if a deadline cannot be met.
9. Where compliance becomes difficult, the landlord should not simply allow the deadline to pass. The correct course may be to communicate promptly, seek agreement where possible, and, if necessary, apply back to the court before the deadline expires. Silence, delay, or incomplete compliance can create serious litigation risk.

The Importance of Penal Notices

Orders requiring parties to do or not do something may contain a penal notice. A penal notice warns the party that breach of the order may lead to contempt proceedings.

Where a landlord receives an order with a penal notice, it should be escalated immediately. It should not be treated as routine correspondence. It should be reviewed by the landlord’s legal team, repairs team, housing management team, and any relevant external contractors.

In practical terms, a landlord should have a compliance plan. That plan should identify the works, the deadline, the contractor, the tenant contact arrangements, and the internal person responsible for ensuring completion. It should also include documentary evidence of completion, including photographs, job sheets, sign-off records, and, where appropriate, expert confirmation.

The failure to manage compliance properly can expose the landlord to costs orders, further enforcement action, and reputational damage.

Practical Lessons for Housing Disrepair Practitioners

For solicitors and advisers acting for tenants, this case demonstrates the importance of precise orders. If a landlord agrees or is ordered to carry out works, the wording should be clear. It should identify the works, the deadline, and, where appropriate, include a penal notice.

Vague obligations are harder to enforce. A clear schedule of works, supported by expert evidence, is more effective. If the case settles, the settlement agreement or Tomlin order should set out the landlord’s repair obligations in a way that can be enforced if necessary.

Where there is non-compliance, practitioners should move promptly. The first step may be a formal warning letter, enclosing evidence and requiring immediate compliance. If that does not work, further court action may be necessary.

For solicitors and advisers acting for landlords, the lesson is equally important. Once an order is made, the priority is compliance. If there is a genuine problem, the court should be approached properly. It is risky to wait until a contempt hearing and then rely on explanations about resources, staffing, access, or operational difficulties.

Does Contempt Require Deliberate Defiance?

A common misconception is that contempt requires a party to deliberately set out to defy the court. The position is more nuanced.

The court will consider whether the order was clear, whether the party failed to do what was required, whether the conduct constituting the breach was intentional, and whether the party knew that the conduct would breach the order. The court must be satisfied to the criminal standard.

In this case, the court accepted that there were practical issues affecting the timing of works. However, it still found that Lambeth had made decisions about the prioritisation of resources and repairs. That was sufficient, on the facts, to establish the necessary intentional element.

This is an important point. Landlords should not assume that contempt can only arise where there is an explicit refusal to comply. Repeated failure to comply with clear orders can be enough, depending on the evidence.

Can A Landlord Avoid Contempt by Completing the Works Late?

Not necessarily. Late completion may be relevant to sanction. It may persuade the court not to impose a severe penalty. It may reduce the practical need for coercive orders. But it does not automatically prevent a finding of contempt.

In Ketrena Francis-Stokes v London Borough of Lambeth, the works had been completed by the final hearing. The court nevertheless found Lambeth in contempt. The court considered that a finding of contempt, together with publication of a neutral summary, was sufficient to vindicate the authority of the court.

That distinction is important. Completion of the works may affect what sanction is appropriate, but it does not necessarily erase the breach.

What should tenants do if a landlord ignores a repair order?

A tenant whose landlord has failed to comply with a repair order should take advice promptly. The appropriate step will depend on the wording of the order, whether it contains a penal notice, what works remain outstanding, and whether the landlord has provided any explanation.

In general, tenants and or their solicitors should keep records of:

1. The court order or settlement agreement.
2. The date by which works were due.
3. All communications with the landlord or managing agent.
4. Any appointments offered or missed.
5. Photographs or videos showing continuing disrepair.
6. The impact on the tenant and household.
7. Any evidence that access was provided or offered.

The tenant should continue to cooperate with reasonable access requests. It is usually important to show the court that the tenant has not prevented the works from being completed.

Conclusion

The decision in Ketrena Francis-Stokes v London Borough of Lambeth is an important reminder that housing disrepair orders must be taken seriously.

A landlord that agrees or is ordered to carry out repairs must ensure that the works are completed within the required period. If it fails to do so, it may face further enforcement action, adverse costs orders, publication of adverse findings, and, in serious cases, a finding of contempt of court.

The case is also a clear example of why failing tenants is in nobody’s interests. Ms Francis-Stokes had to pursue her landlord over a prolonged period to secure works that had already been agreed and then ordered by the court. The Defendant had previously paid significant costs and disbursements, was ordered to pay indemnity costs of more than £14,000 in the contempt proceedings before the April hearing, and was then ordered to make a further payment on account of costs following the final contempt hearing.

Where the landlord is a local authority, these costs do not exist in a vacuum. They are paid from public resources. Avoidable delay in dealing with disrepair therefore risks causing harm to tenants while also imposing unnecessary cost on the public purse.

The wider lesson is simple. Housing disrepair should be dealt with early, properly, and in accordance with any agreement or court order. Court orders are not optional. Where they are ignored or repeatedly missed, eventual compliance may not be enough to avoid serious consequences.

Frequently Asked Questions About Injunctions and Contempt of Court

What is a housing disrepair injunction?

A housing disrepair injunction is a court order requiring a landlord to carry out specified repair works. It may be made where a landlord has failed to comply with its repairing obligations and the court considers that an order requiring works is necessary.

What happens if a landlord does not comply with a disrepair injunction?

If a landlord does not comply with a disrepair injunction, the tenant may be able to take enforcement action. Depending on the wording of the order, this may include further applications to the court and, in serious cases, contempt proceedings.

Can a council be found in contempt of court?

Yes. A local authority or council can be found in contempt of court if the legal test is met. The fact that the landlord is a public authority does not mean it can ignore court orders.

Does the landlord have to deliberately refuse to comply?

Not necessarily. The court will consider whether the order was clear, whether the landlord failed to do what was required, whether the conduct constituting the breach was intentional, and whether the landlord knew that its conduct would breach the order. Each case depends on its facts.

Can the landlord avoid contempt by doing the works before the hearing?

Late completion may help reduce the sanction, but it does not automatically prevent a contempt finding. If there has already been a serious or repeated breach of court orders, the court may still find contempt.

What should tenants do if repairs are not completed by the deadline in a court order?

Tenants should keep careful evidence, continue to provide reasonable access, and seek legal advice promptly. The court will usually need clear evidence of what was ordered, what was not done, and what steps the tenant took to cooperate.

Why is this case important?

This case is important because it shows that landlords, including local authorities, may face a contempt finding where they repeatedly fail to comply with clear court orders requiring repair works. It also shows that eventual completion of works does not necessarily excuse earlier non-compliance.