The King's Bench Division dismissed an application to set aside an extended civil restraint order (the ECRO). The applicant had instructed solicitors to represent him in a personal injury claim and, following the solicitors' termination of the conditional fee agreement, a bankruptcy order had been made against the applicant, concerning unpaid legal fees. The applicant had made several applications to the County Court to set aside the bankruptcy order which had been dismissed, as totally without merit. His applications against the trustee in bankruptcy (F) had also been dismissed, and, notwithstanding that three ECROs had been made against the applicant, he had issued a further application notice, seeking permission to bring a fresh claim against the respondent Official Receiver (the OR) and F, concerning 'allegations of breach of duty in the managing of his bankruptcy'. The ECRO in question had then been made. The court held, among other things, that: (i) there was no proper basis for setting aside the ECRO, which had properly been made; (ii) Henderson abuse precluded a party from raising in subsequent proceedings matters which were not, but could and should have been, raised in the earlier ones and, accordingly, it would not be fair to permit the applicant to litigate another claim against the OR or F, arising out of exactly the same factual scenario as the earlier claims, especially given the significant delay since the key events and the number of times the applicant had sought to litigate (and had litigated) the issue in various guises; (iii) the allegation of a breach of r 6.125(7) of the Insolvency Rules 1986, SI 1986/1925, was merely another way of seeking to challenge the actions of the OR with respect to a disclaimer issue and it was squarely caught by an earlier judgment, such that even if the applicant was not precluded from pursuing the allegation by virtue of issue estoppel, it would be an abuse of process in the Henderson sense to permit him to do so; (iv) a claim against the OR in relation to section 323 of the Insolvency Act 1986 (IA 1986) (mutual credit and set off) would constitute a Henderson abuse; and (v) to the extent that the applicant sought to litigate the alleged failure of the district judge to apply the duty under IA 1986, s 323 through a free-standing civil claim against the Lord Chancellor, the same would also constitute a Henderson abuse, and it would also be totally without merit, not least because judicial office holders were immune from negligence claims arising out of their judicial functions.