Lawsuit: Dismissed PhillinDeBlanc v. Crown, Case 10 (Ch. 2025)

[PhillinDeBlanc]

IN THE HONOURABLE CHANCERY
OF THE SOVEREIGN KINGDOM OF ALEXANDRIA

Case No.: 10

BETWEEN:

PHILLINDEBLANC
(Operating Sanctum Exchange Corporation)
Plaintiff

v.

THE CROWN OF THE KINGDOM OF ALEXANDRIA
Defendant

COMPLAINT

I. JURISDICTIONAL STATEMENT

1. This Court has jurisdiction over this suit pursuant to the Alexandrian Constitution Part III, Section 15. Specifically, Section 15 grants this Court exclusive jurisdiction over constitutional questions and matters arising from the interpretation and application of Parliamentary Acts.

II. PARTIES

1. PhillinDeBlanc (hereinafter "Plaintiff") is an individual seeking to register Sanctum Exchange Corporation, intended to be the largest commodities exchange in Alexandria. Sanctum Exchange Corporation is currently operating but requires formal registration to pursue further business development, including public listing.
2. The Crown of the Kingdom of Alexandria (hereinafter "Defendant" or "the Crown") is the legal body recognized for proper service of suits alleging constitutional violations and ultra vires actions by its Ministries. See Reallmza v. The Crown, Case 1 (Ch. 2025).

III. FACTS

1. The Parliament of Alexandria enacted the Legal Entity Act (A.P.020) (hereinafter "LEA"), which provides for the formation and regulation of legal entities, including Corporations.
2. Section 7 of the LEA outlines the mandatory process for the formation of a Corporation:
   • Section 7(3)(a): "The Incorporators shall file a Certificate of Incorporation."
   • Section 7(3)(c): "The Ministry of Trade and Finance shall verify the Certificate of Incorporation for compliance within 5 days."
   • Section 7(3)(d): "The Ministry of Trade and Finance shall be liable to pay $50 every begun day exceeding this limit to the Incorporators."
   • Section 7(3)(e) provides limited, specific reasons for extending this time limit ("complexity of the Certificate of Incorporation" or "an exceedingly high amount of filings"), neither of which has been cited by the Ministry of Trade and Finance (hereinafter "MoTF") in the current matter.
3. On or around May 29th, Omegabiebel, the Minister of Trade and Finance, announced via official channels a "PAUSE ON LEGAL ENTITY REGISTRATION," stating: "The MOTF is still setting up the infrastructure needed for the registration of legal entities so until further notice the registration of legal entities is CLOSED." (Evidence of this announcement is available and will be produced.)
4. The Plaintiff, on behalf of Sanctum Exchange Corporation, had either submitted or was prepared to submit a Certificate of Incorporation for registration in accordance with Section 7 of the LEA.
5. Due to the MoTF's announced pause, the Plaintiff is unable to complete the legal registration of Sanctum Exchange Corporation.
6. Section 12 of the LEA, titled "Power of the MOTF," enumerates the powers granted to the MoTF. These powers include maintaining the Company Registry (Sec 12.1), creating rules and regulations essential for enforcing the act (Sec 12.2), disbanding inactive sole proprietorships (Sec 12.3), and executing forced dissolutions of incorporated entities (Sec 12.4).
7. The LEA does not explicitly or implicitly grant the MoTF the power to unilaterally suspend or pause the entire process of new legal entity registration as mandated by Section 7 and other provisions of the Act.

IV. CLAIMS FOR RELIEF

COUNT I: ULTRA VIRES ACTION BY THE MINISTRY OF TRADE AND FINANCE
11. Plaintiff realleges and incorporates paragraphs 1 through 10 as if fully set forth herein.
12. The MoTF is a creature of statute and may only exercise powers expressly or implicitly granted to it by Parliament through legislation such as the LEA.
13. The general pause on legal entity registrations announced by the MoTF is not an enumerated power under Section 12 of the LEA, nor can it be reasonably implied from the powers granted, particularly the power to create rules for "enforcing this act" which presumes the Act is in operation.
14. The MoTF's duty to verify Certificates of Incorporation within 5 days, as mandated by Section 7(3)(c) of the LEA, is a positive obligation. A failure to provide resources or "set up infrastructure" to meet this statutory duty does not grant the MoTF the authority to suspend this duty entirely.
15. Therefore, the MoTF's pause on legal entity registrations is an act ultra vires, exceeding its lawful authority.

COUNT II: FRUSTRATION OF STATUTORY RIGHTS AND ECONOMIC HARM
16. Plaintiff realleges and incorporates paragraphs 1 through 15 as if fully set forth herein.
17. The LEA, particularly Section 7, creates a statutory pathway and an expectation for individuals and businesses like the Plaintiff's to form and register Corporations.
18. The MoTF's unlawful pause directly prevents the Plaintiff from exercising his statutory right to seek registration for Sanctum Exchange Corporation.
19. As a direct and proximate result of this inability to register, Sanctum Exchange Corporation has suffered and continues to suffer significant economic harm. Specifically:
a. Sanctum Exchange Corporation is unable to proceed with a planned Initial Public Offering (IPO) to raise approximately £10,000 in capital, as legal registration is a prerequisite for listing on the New Hamilton Stock Exchange.
b. The inability to raise capital impedes the growth, operational capacity, and market development of Sanctum Exchange Corporation, which has an estimated current market value of approximately £50,000.
c. The delay causes ongoing financial loss, missed opportunities, and damages the business's momentum and reputation.

V. PRAYER FOR RELIEF

WHEREFORE, Plaintiff respectfully requests that this Honourable Court:

A. Declare that the Ministry of Trade and Finance’s announced pause on legal entity registration is ultra vires and unlawful.
B. Issue a mandatory injunction compelling the Ministry of Trade and Finance to immediately cease its pause on legal entity registrations and to process submitted Certificates of Incorporation, including that of Sanctum Exchange Corporation, in accordance with the timelines and procedures set forth in the Legal Entity Act.
C. Award damages to the Plaintiff for the economic harm suffered as a result of the unlawful pause, in an amount to be proven at trial.
D. Award costs of this suit.
E. Grant such further and other relief as this Court deems just and proper.

RESPECTFULLY SUBMITTED,

---

PhillinDeBlanc
Plaintiff

Dated: 06/12/25

 

[PhillinDeBlanc]

IN THE HONOURABLE CHANCERY
OF THE SOVEREIGN KINGDOM OF ALEXANDRIA

Case No.: 10

BETWEEN:

PHILLINDEBLANC
(Operating Sanctum Exchange Corporation)
Applicant/Plaintiff

v.

THE CROWN OF THE KINGDOM OF ALEXANDRIA
Respondent/Defendant

REQUEST FOR URGENT INTERIM RELIEF​

The Applicant, PhillinDeBlanc, hereby respectfully moves this Honourable Court for an Order granting urgent interim relief pending the final determination of this matter, and alleges as follows:

1. Prima Facie Case: The Applicant has a strong prima facie case that the Ministry of Trade and Finance (MoTF) has acted ultra vires by imposing a general pause on legal entity registrations. As detailed in the main Complaint and supported by the Legal Entity Act (LEA), particularly Sections 7 and 12, the MoTF lacks the statutory authority for such a blanket suspension. Section 7 of the LEA imposes a mandatory duty on the MoTF to process applications for incorporation within a specified timeframe, offering limited exceptions not applicable here.
2. Irreparable Harm: The Applicant and Sanctum Exchange Corporation will suffer immediate and irreparable harm if the interim relief is not granted.
   a. Sanctum Exchange Corporation is actively operating and poised for significant growth, which is currently stalled by the inability to register.
   b. Specifically, the pause prevents Sanctum Exchange Corporation from proceeding with a time-sensitive Initial Public Offering (IPO) valued at approximately £10,000 on the New Hamilton Stock Exchange. This opportunity to raise crucial capital may be lost or significantly diminished by delay.
   c. The inability to secure this funding directly impacts the corporation's ability to expand operations, compete effectively, and realize its market potential (current estimated value ~ £50,000). Such lost opportunities and stunted growth are difficult, if not impossible, to quantify and compensate fully with monetary damages at a later date.
   d. Continued delay erodes business momentum and may damage the reputation of Sanctum Exchange Corporation among potential investors and market participants.
3. Balance of Convenience: The balance of convenience overwhelmingly favors the Applicant. The harm to the Applicant and Sanctum Exchange Corporation from the continued unlawful pause is substantial and ongoing. Conversely, the inconvenience to the MoTF in complying with its statutory duty to process registrations is a burden legislatively imposed and anticipated by the LEA itself (including provisions for reasonable extensions under specific circumstances not invoked here, and penalties for non-compliance with verification timelines). The public interest also lies in the lawful and efficient administration of business registrations.
4. Urgency: The matter is urgent due to the ongoing financial harm and the time-sensitive nature of the planned IPO. Each day the unlawful pause continues to exacerbate the damage to Sanctum Exchange Corporation's financial prospects and strategic objectives.

THEREFORE, THE APPLICANT PRAYS FOR AN URGENT INTERIM ORDER:

A. Directing the Ministry of Trade and Finance to immediately lift its general pause on legal entity registrations.
B. Directing the Ministry of Trade and Finance to forthwith accept and process the submission of the Certificate of Incorporation for Sanctum Exchange Corporation, and other similarly situated entities, in accordance with the procedures and timelines mandated by the Legal Entity Act, pending the final resolution of this Complaint.
C. Such further and other relief as this Honourable Court deems just and equitable in the circumstances.


PhillinDeBlanc

RESPECTFULLY SUBMITTED TO THE CHANCERY.

Dated: 06/12/25

 

[Smallfries]

IN THE CHANCERY OF
THE KINGDOM OF ALEXANDRIA
WRIT OF DISMISSAL
​

Memorandum Opinion by Chancellor Smallfries, joined by Chancellor Kaiserin_

The Chancery does not hear any and all matters of vague constitutionally-relevant concern. The mere scintilla of a constitutional violation or whiff of presence of constitutional issue does not immediately demand our attention, nor do we stake ultimate and unceasing claim over any dispute the moment a constitutional provision is thought of. To be raised directly to the Chancery of Alexandria, a case based in constitutional concern must be a constitutional question or concern the interpretation or application of the Constitution.

The matter at hand is neither of those things. Could a constitutional violation be hidden within the alleged action? Perhaps. But there is no sound reason why the lower court could not handle it themselves. In the instant case, it is alleged that a government body is exercising authority outside that which is expressly given to it by Parliament. If we were to accept this case at this time, we would be accepting the notion that any time an entity acts outside the bounds written in law by Parliament, that alleged un-permitted action is necessarily a constitutional violation and a question arising directly out of the Constitution. This is obviously ludicrous.

Multiple interpretations can exist regarding what Parliament may or may not have meant or implied with various statutes. Claimant, it would seem, would have us mandate by law that any time one entity acts against what another entity believes is the "correct" interpretation of Parliament's will, that issue should immediately be placed under scrutiny by this court as a constitutional conundrum. This surely is not what the Constitution intended when it said "exclusive jurisdiction over constitutional questions, including the interpretation and application of the Constitution." See K. A. Const. § III Art. 15. Instead, this court takes the position that "constitutional questions, including the interpretation and application of the Constitution" means that our original and exclusive jurisdiction over constitutional issues arises when an issue is born solely or almost entirely out of the Constitution itself, or the interpretation or application thereof.

This is an important and necessary distinction to make. Were we to accept that any such case could and should be sent immediately to us, it is sure that the Magistrates Court would find itself quickly bereft of cases, while we find ourselves swamped with work. This focus on administrability and the judicial economy benefits all parties involved, as the litigants are able to appeal if they dislike the outcome, the Magistrate(s) involved have an opportunity to flex their legs and apply new theories, and we on the Chancery get to have a fresh perspective—the Magistrate's—apply their thoughts before the issue is appealed to us.

The logical outcome, then, is that our original and exclusive jurisdiction regarding constitutional issues is those issues that arise directly, necessarily, and (at least almost) solely out of the Constitution as a body of law itself. The mere interpretation of law passed by Parliament, or alleged unconstitutional or otherwise unlawful action by a governmental body, or other incident whose constitutionality is merely incidental to the true matter at hand is not grounds for immediate Chancery appraisal.

The Constitution is not perfect. There are issues—many of them—and everyone continues to do the best we can with what we have. It is important to make matters as workable as possible, and not allow a narrow view without any foresight to be applied and blindly guide us over a cliff to our doom. However, if none of the above is particularly convincing, one thing should be: the Claimant very clearly misstates the law, almost to a point where it is hard to say willful ignorance did not play a hand. The Constitution does not say we shall adjudicate in matters arising from the interpretation and application of acts of Parliament, but rather interpretation and application of the Constitution itself. These are completely different phrases, and they have vastly different meanings. It is clear to us that this difference of meaning necessarily states that only those issues which originate within the Constitution itself belong solely to us. We do not intend to interpret the Constitution to say that the interpretation and application of any act of Parliament is necessarily our original and exclusive jurisdiction.

Thus, we refuse both the Claimant's demand for Emergency Relief, and to grant this case an audience at this time at all. We dismiss this case without prejudice and remand it to the Magistrates Court for further proceedings.