Court of Appeal reverses Mazur ruling, confirming supervised non-solicitors can conduct litigation work and resolving a year of uncertainty for alternative legal service providers
The Court of Appeal has reversed the first-instance Mazur ruling, holding that supervised non-solicitors are permitted to carry out litigation work. The decision offers significant reassurance to law firms and alternative legal service providers (ALSPs) — businesses that deliver legal services using non-lawyer personnel — whose operating models had faced acute scrutiny following the original judgment. The lower court ruling in Mazur had cast doubt on whether paralegals and other non-qualified staff could lawfully conduct litigation tasks even under the supervision of a qualified solicitor, threatening to disrupt a wide range of business models that have grown up around the post-Legal Services Act 2007 regulatory framework. The Court of Appeal's reversal clarifies that the reserved legal activity of 'conducting litigation' does not require every step in a case to be performed personally by a qualified solicitor — supervision is a sufficient safeguard. Firms involved include 4 New Square, Blackstone Chambers, Charles Russell Speechlys, Fountain Court Chambers, Kingsley Napley, and Russell-Cooke. The Solicitors Regulation Authority (SRA) was named as a company party to proceedings. The ruling has immediate practical significance for firms operating mixed teams of solicitors and paralegals on high-volume litigation, and for the growing market of managed legal services providers deploying non-qualified reviewers on large disclosure and due diligence exercises.
Why this matters
The Court of Appeal's reversal directly protects the operating models of a significant part of the UK legal market — ALSPs, managed legal services providers, and any firm running mixed solicitor-paralegal litigation teams. Had Mazur stood, it would have required either mass qualification of existing paralegal staff or a fundamental restructuring of how litigation services are delivered and priced. The ruling also carries indirect significance for AI-assisted litigation workflows, where the division of labour between qualified lawyers and supervised automated tools or non-qualified reviewers is increasingly commercially important. The 'why now' context is the broader policy tension between access to justice (which favours lower-cost supervised delivery) and professional standards (which the SRA defends through reserved activities). For firms advising ALSPs or those operating such models themselves, this judgment is the highest-authority confirmation their structures are lawful.
On the Ground
On appeals of this kind, a trainee would prepare disclosure review and categorisation schedules for the bundles filed before the Court of Appeal, assist with witness statement bundles and chronology preparation capturing the litigation history from first instance, and handle court filing and service of the appeal documents and any consequential orders.
Interview prep
Soundbite
Mazur reversed: paralegals can conduct supervised litigation — the ALSP market's legal foundation just got Court of Appeal endorsement.
Question you might get
“Under the Legal Services Act 2007, what are the 'reserved legal activities', and why does the distinction between who can perform them and who can supervise them matter commercially for law firm business models?”
Full answer
The Court of Appeal has overturned the Mazur ruling, confirming that supervised non-solicitors can lawfully carry out litigation work — resolving what had become an existential legal question for a substantial part of the UK legal services market. The original Mazur decision had threatened to void the operating models of managed legal services providers and law firms running high-volume paralegal-led litigation teams, by suggesting that 'conducting litigation' as a reserved activity required personal performance by a qualified solicitor. The Court of Appeal's clarification that supervision is a sufficient safeguard aligns with the policy intent of the Legal Services Act 2007, which was designed to promote competition and access to justice through diversified delivery models. This matters commercially because it unlocks continued investment in ALSP and managed services platforms and maintains the viability of paralegal-heavy pricing models in litigation. The SRA's involvement as a party signals the regulatory significance the profession attached to the outcome.
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