The High Court of England and Wales has dismissed the second reported judicial review of Section 4L of the British Nationality Act 1981, the citizenship good character rule that took effect in 2022. The judgment, R (on the application of Akinyemi) v Secretary of State for the Home Department [2026] EWHC 2388 (Admin), leaves the statutory framework intact.

What does Section 4L require?

Section 4L took effect in 2022. The provision governs the good character requirement the Secretary of State must apply when considering an application for registration as a British citizen. Applicants must satisfy the test before the Home Department will register them.

Who brought the challenge?

The claimant was born in the UK and has an extensive record of offending. He brought a judicial review against the Secretary of State for the Home Department, challenging the refusal of his application to register as a British citizen. He argued that the Home Department applied Section 4L in a way that produced an unlawful outcome in his case.

His application is the second reported judicial test of the provision's operation since 2022.

What did the court decide?

The High Court dismissed the claim. The judgment rejects the legal arguments advanced. The Secretary of State's discretion to refuse registration on character grounds continues without modification.

What does the ruling mean for other applicants?

The judgment carries several practical consequences for practitioners and applicants:

• Section 4L remains the operative character test for registration applications
• The Home Department's refusal grounds stand without modification
• Each application still requires a fact-specific good character assessment
• The judgment adds to a small but growing body of case law on the provision

The ruling does not create a precedent that automatically assists other refused applicants. A long-standing offending record, as the claimant had here, will continue to weigh heavily in any character assessment.

Why does the ruling matter for case law?

This is the second reported decision on Section 4L since enactment in 2022. The earlier ruling set the first precedent for how the provision operates in practice. Reported decisions on this section remain limited in number, making each new ruling of clear interest to citizenship practitioners advising clients with criminal convictions.

Where is the official judgment published?

The full judgment appears as [2026] EWHC 2388 (Admin). Practitioners and applicants can access it through the British and Irish Legal Information Institute (BAILII) and the National Archives' Court Judgments service. Those primary sources set out the precise terms of the court's reasoning.

What should refused applicants do next?

The dismissal means the Secretary of State's refusal of Mr. Akinyemi's application stands. Applicants facing similar refusals under Section 4L can seek independent legal advice from a qualified immigration solicitor. A solicitor can review the specific facts of any case and advise on available avenues for further challenge.

Applicants should not treat this case as a route to overturn their own refusal. Each claim turns on its own evidence and the statutory language of Section 4L itself. The official Home Office guidance on citizenship good character requirements remains the primary reference point for current policy. Anyone weighing an application should base their planning on that published guidance.