Reasonable-Explanation Threshold for Late Execution of Circuit Court Possession Orders under Order 36

Case: Pepper Finance Corporation (Ireland) DAC v O'Donnell & Anor (Approved) [2026] IEHC 528 (High Court, Cahill J., 27 July 2026)

Appeal from: Circuit Court (County Tipperary), order perfected 30 July 2025

1) Introduction

The High Court determined an appeal from Circuit Court orders (i) substituting Pepper Finance Corporation (Ireland) DAC (“Pepper”) as plaintiff in place of a prior charge-holder, and (ii) granting Pepper leave to issue execution of a Circuit Court possession order over registered land in County Tipperary.

The underlying mortgage loan originated in 2004. The borrowers stopped repaying in 2014, with substantial arrears and an overall balance outstanding. A possession order was granted in 2017 to the then charge-holder (Shoreline Residential Ltd.), subject to a nine-month stay. After a later transfer of the mortgage assets and registration of Pepper as owner of the charge, Pepper sought substitution and permission to execute the 2017 possession order in 2025.

Two core issues arose:

  • Substitution / title: whether Pepper proved, to the correct standard, that legal title to the loan and mortgage transferred to it (not merely registration of the charge).
  • Late execution: whether leave should be granted to execute the possession order more than six years after it was made, given the time elapsed and the explanations offered.

2) Summary of the Judgment

2.1 Outcome

  • Substitution: Appeal dismissed; substitution of Pepper as plaintiff confirmed.
  • Leave to execute: Appeal allowed; the Circuit Court’s grant of leave to issue execution set aside.
  • Costs: Court indicated a provisional view of no order as to costs, with directions for short written submissions.

2.2 Key findings in brief

  • Substitution is procedural, but proof is required: applying Bank of Scotland v McDermott [2019] IECA 142, the transferee seeking substitution after judgment must prove transfer of the relevant interest on the balance of probabilities.
  • Register is conclusive as to the charge, not necessarily the debt: while the Land Registry is conclusive as to charge ownership (per Tanager DAC v. Kane [2018] IECA 352), the register does not conclusively establish succession to the underlying debt (per Permanent TSB plc v. Donohoe [2025] IECA 222).
  • Late execution requires a reasonable explanation for the entire lapse: applying Smyth v. Tunney [2004] 1 IR 512 as refined by Ulster Bank Limited v. Quirke [2022] IECA 283 and Cabot Financial (Ireland) Limited v. Joyce [2023] IECA 281, the creditor must cross a threshold by providing a reasonable explanation covering the entire period of delay. Only then does discretion arise to consider prejudice.
  • Generic, infrequent contact attempts were insufficient: four standard letters over roughly four years (with long unexplained gaps) did not amount to a reasonable explanation for the delay in seeking execution.

3) Analysis

3.1 Statutory and procedural framework

(a) Substitution in the Circuit Court

Substitution was sought under Order 22, rule 4 of the Circuit Court Rules, permitting a new party to be added where, after commencement, there is an event causing a “change or transmission” of interest such that it is necessary or desirable that the proceedings continue in the name of the successor.

(b) Execution out of time in the Circuit Court

The execution issue turned on Order 36, rules 9 and 10 of the Circuit Court Rules (as substituted by the Circuit Court Rules (Order 36) 2024). In essence:

  • Execution may issue “as of course” within six years from the decree/judgment.
  • After six years, execution requires leave of the court, sought by motion on notice.
  • If there has been a change in the party entitled to execution (e.g., assignment), the successor must seek leave and the judgment may be amended to give effect to the order.

The Court treated the well-developed Superior Court jurisprudence on Order 42, rules 23–24 RSC as applicable by analogy, consistent with Mars Capital Ireland DAC v. Hunter [2022] IEHC 353.

(c) Registered land and charges

The decision repeatedly engaged the distinction between:

  • Title to the charge over registered land (where the register is conclusive: section 31, Registration of Title Act 1964); and
  • Succession to the debt/loan (which may require separate proof, and is not conclusively established by charge registration: Permanent TSB plc v. Donohoe [2025] IECA 222).

3.2 Precedents cited and how they shaped the decision

(A) Substitution and proof of transfer after judgment

Bank of Scotland v McDermott [2019] IECA 142 was the central substitution authority. The Court adopted Peart J.’s framing that substitution is “purely procedural” and should not become a “mini-trial,” but when substitution is sought after judgment the correct standard is the ordinary civil standard: balance of probabilities (distinguishing the prima facie approach mentioned in IBRC v. Comer).

Cahill J. applied that approach: Pepper exhibited an unredacted deed of transfer (with only third-party schedule data appropriately redacted), prior transfer documentation to Shoreline, Land Registry folio evidence showing Pepper registered as charge owner, and “hello/goodbye” letters matching the loan account details. On that evidence, and in the absence of any credible contrary basis, the Court held the transfer of the loan and mortgage to Pepper was proved on the balance of probabilities.

(B) Conclusiveness of the register: charge title vs debt succession

Tanager DAC v. Kane [2018] IECA 352, [2019] 1 IR 385 was cited for the proposition that, in possession proceedings concerning registered land, the court cannot entertain a challenge to the correctness or conclusiveness of the register as to ownership of the charge.

Pepper relied on Pepper Finance Corporation (Ireland) DAC v. Maloney [2023] IECA 161 and section 64(4) of the Registration of Title Act 1964 (transferee of a registered charge has the same powers as if originally created in its favour) to argue that registration alone was sufficient.

Cahill J. carefully confined Maloney to its facts. In Maloney, the entity that obtained the possession order and the entity later seeking execution were found to be the same legal person (a corporate identity/succession point addressed under the Companies Act 2014, not an assignment between different entities). The judgment in Maloney therefore did not decide whether a transferee relying on an assignment between different entities could dispense with proving succession to the loan.

The Court then aligned its approach with Permanent TSB plc v. Donohoe [2025] IECA 222, where the Court of Appeal confirmed that the register does not conclusively determine succession to the debt; in a possession context the court must consider whether legal title to the loan, as well as the charge, passed. In this case, Pepper ultimately succeeded because it did adduce evidence of the loan transfer, rather than relying on registration alone.

(C) Late execution: Smyth v Tunney and the Quirke/Cabot clarifications

The governing test for execution after six years remained Smyth v. Tunney [2004] 1 IR 512, but the judgment treated the modern controlling elaborations as those in Ulster Bank Limited v. Quirke [2022] IECA 283 and Cabot Financial (Ireland) Limited v. Joyce [2023] IECA 281.

Cahill J. extracted and applied a structured set of propositions from Quirke and Cabot, including:

  • Threshold first: a court’s discretion to grant leave arises only if the creditor first provides a reasonable explanation for the delay (Cabot endorsing Quirke).
  • Entire period must be explained: the explanation must cover the whole lapse from judgment date to application date, including the initial six years (Quirke).
  • Not a box-ticking exercise: the court must assess the nature and quality of the explanation; it is not enough that “some reason” is asserted (Cabot).
  • Engagement policy balanced with expedition: there is a public interest in encouraging negotiations, but also an interest in expedition in enforcing judgments (citing Hayde v H & T Contractors Ltd. [2021] IEHC 103 as endorsed in both Quirke and Cabot).
  • Marketability of debts not an objective of the rule: the Court adopted Cabot in rejecting arguments based on protecting debt marketability as irrelevant to Order 42/Order 36 rationale.

(D) Comparator repossession execution cases: Start Mortgages line and Hunter

Pepper relied on a series of High Court decisions granting leave to execute possession orders, notably: Start Mortgages DAC v. Hendrick [2023] IEHC 11, Start Mortgages DAC v. Gawley [2023] IEHC 37, Start Mortgages DAC v. McInerney [2023] IEHC 155, and Start Mortgages DAC v. Hanley [2023] IEHC 387.

Cahill J. distinguished these comparators on their factual texture: they involved (i) prior grants of leave (so the focus was shorter subsequent periods), (ii) appeal-related delays, (iii) more sustained and documented engagement, and (iv) in some instances repayments or specific solution pathways (mortgage-to-rent, personal insolvency). The Court treated Mars Capital Ireland DAC v. Hunter [2022] IEHC 353 as illustrating that the court looks to whether enforcement steps/communications were such that a debtor would not be “lulled” into thinking the order had been abandoned.

(E) Authorities rejected as misapplied in this procedural posture

The borrowers invoked delay jurisprudence associated with strike-out for want of prosecution, including Primor plc v. Stokes Kennedy Crowley [1996] 2 IR 459 and Kirwan v. Connors [2025] IESC 21. Cahill J. rejected this as misconceived: an application for leave to execute in concluded proceedings is distinct from dismissal for delay in ongoing litigation, echoing Cabot and Hunter.

3.3 Legal reasoning and application to the facts

(A) Substitution

Applying Bank of Scotland v McDermott, the Court treated substitution as procedural but requiring proof of transmission of interest on the balance of probabilities. Pepper’s evidence (transfer deeds, folio registration, and matching account correspondence) was sufficient. The borrowers did not raise a substantive or credible basis to rebut the documentary chain. Accordingly, substitution was confirmed.

Importantly, the Court did not finally determine whether charge registration alone is always sufficient to justify substitution. Instead, it proceeded on the basis that Pepper accepted the burden to show title to the loan and mortgage and had done so.

(B) Leave to execute (the dispositive issue on appeal)

The possession order dated from July 2017; the motion seeking leave issued in April 2025 (about 7 years and 9 months later). The Court rejected an attempt to reframe the calculation as running only from the expiry of the stay: the six-year period runs from the date of the order, although the stay provided an obvious explanation for early non-enforcement.

Pepper advanced three explanations: (1) an execution order obtained in March 2019; (2) Covid-related moratorium and “pandemic” conditions; and (3) contact/engagement letters from 2021–2024.

Cahill J. accepted that the March 2019 execution order showed some intention to enforce, and accepted that the Covid moratorium (from March to September 2020) reasonably explained non-enforcement during that period, with some additional allowance for pandemic-related conditions thereafter.

However, the core deficiency was the period from roughly March 2021 to April 2025. The evidence of engagement consisted of four letters over four years, with significant gaps (including an unexplained 20-month period and then a further 14-month period before the motion). The letters were described as relatively generic and not showing individualised, solution-focused, ongoing engagement of the type seen in the comparator cases. There was also no engagement from the borrowers and no repayments since 2014.

Applying Cabot and Quirke, the Court held this did not amount to a reasonable explanation covering the entire lapse of time. Because the threshold was not met, no discretion arose to consider prejudice, “marketability of debts,” or the risk of the order becoming statute-barred. Leave to execute was therefore refused.

(C) Collateral challenges to the underlying possession order

The borrowers attempted to invoke Council Directive 93/13/EEC (unfair terms). The Court treated this as an impermissible collateral attack on an unappealed, existing possession order, and in any event not an issue that could be raised on an application to execute that order.

3.4 Impact and significance

(A) Practical impact for lenders and loan purchasers

  • Document the entire enforcement narrative: a creditor seeking late execution must be able to evidence a reasonable explanation for the whole period post-order. Sporadic, generic communications are unlikely to suffice, especially where there is no debtor engagement and no payments.
  • Pandemic reliance is time-limited: Covid moratoria may explain discrete windows of inactivity, but do not, without more, rationalise multi-year gaps with minimal activity.
  • Threshold discipline: arguments about prejudice, fairness, market impact, or limitation consequences will not be reached unless the creditor first crosses the reasonable-explanation threshold.
  • Substitution still demands a transfer proof: even with charge registration, prudent practice is to exhibit the transfer instruments and supporting linkage (account identification, chain of title), consistent with the Court’s reading of Permanent TSB plc v. Donohoe.

(B) Impact for borrowers

  • A procedural but real protection: Order 36’s six-year rule operates as more than a formality; creditors must justify late enforcement with a reasoned, evidence-based account.
  • But not a re-litigation avenue: execution proceedings are not a forum for re-opening the merits of the possession order (including consumer-contract arguments that could have been raised earlier).

(C) Doctrinal significance

The judgment is a clear High Court application of the Court of Appeal’s modern approach in Quirke and Cabot to the Circuit Court context, confirming that: (i) Order 36 applications are governed by the same threshold logic as Order 42, (ii) the court must evaluate the adequacy (not merely existence) of reasons, and (iii) the “reasonable explanation” requirement has operational bite in repossession enforcement.

4) Complex Concepts Simplified

Concept Plain explanation (as used in this judgment)
Charge (registered land) A registered security interest over land (a mortgage-type security). The Land Registry folio records the charge-holder. Under section 31 of the 1964 Act, the register is conclusive as to what it records.
Succession to the debt Who is legally entitled to the underlying loan (the borrower’s repayment obligation). The Court emphasised that registration of the charge does not necessarily prove who owns the debt.
Substitution A procedural order replacing one party with another (e.g., where a loan/charge has been transferred) so the correct entity is on the record to take steps in the case.
Execution / leave to execute “Execution” is the process of enforcing a court order (here, enforcing a possession order). If more than six years have passed, leave of the court is required under Order 36.
Balance of probabilities The ordinary civil standard: whether something is more likely than not. Applied to proof of transfer for substitution after judgment.
Reasonable explanation threshold A creditor seeking late execution must provide an explanation that is reasonable and of substance for the whole period of delay; only if that threshold is met does the court move to consider prejudice and exercise discretion.
Collateral attack An attempt to challenge the correctness of an existing, unappealed order in later enforcement-related proceedings. The Court rejected attempts to re-open the merits at the execution stage.

5) Conclusion

Pepper Finance Corporation (Ireland) DAC v O'Donnell & Anor [2026] IEHC 528 confirms two practical propositions in mortgage enforcement litigation. First, a post-judgment successor can be substituted where it proves, on the balance of probabilities and by proper documentation, that the loan and mortgage interest transferred to it. Second—and more significantly—the High Court applied Quirke and Cabot to hold that leave to execute a possession order outside six years will be refused unless the creditor provides a reasonable, evidence-based explanation covering the entire delay; sporadic, generic communications and long periods of inactivity will not meet that threshold.