The case of Mercury Tax Group Ltd & Anor, R (on the application of) v HM Commissioners of Revenue & Customs & Ors [2008] EWHC 2721 (Admin) (13 November 2008) deals with Signing Documents Through The Signature Page.

It covers the matter of taking a signature page that has been signed and then attaching it to the final version of a document and extended to substitution of the signature page in a later version of the document deployed.

The issue at large is what happens if there is a later dispute over the integrity of the document.

Signing Documents Through The Signature Page

Judgment Highlights

Judgment Highlights

I cannot accept the Claimants’ primary case that the substitution of the signature pages had no effect on the validity of the contracts in question or, thus, of the Scheme as a whole. I accept that the flaws on which HMRC rely are essentially formal. But I see nothing wrong in applying a strict test of formality to the validity of the agreements with which we are concerned in this case. Their entire raison d’être is to create – and demonstrably to create – a series of formal legal relationships: if they do not do that, they do nothing.

… Mr Bird submitted, and I agree, that that language necessarily involves that the signature and attestation must form part of the same physical document

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Author: Elliot Green
Last Updated: August 17, 2026

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