The High Court’s judgment in R (on the application of Palmer) v Northern Derbyshire Magistrates’ Court [2021] EWHC 3013 held that an insolvency practitioner appointed as an administrator of a company can be found criminally liable under section 194 of the Trade Union and Labour Relations (Consolidation) Act 1992 (“TULRCA”), for not notifying the secretary of state about proposed redundancies.