The Argus has been given an exclusive preview of the High Court battle which could free killer millionaire Nicholas Hoogstraten.

Lawyers for the disgraced property tycoon have won the right to appeal against his conviction and sentence for the manslaughter of business associate Mohammed Raja.

The Argus has been given a copy of the 32-page dossier issued to the High Court containing details of their grounds of appeal.

Hoogstraten was found guilty of the manslaughter of Mr Raja last July and is serving a ten-year prison sentence.

A jury at the Old Bailey decided Mr Raja was shot and stabbed by two men - David Croke and Robert Knapp - hired by the millionaire landlord but ruled he did not order the murder.

The dossier, compiled by Hoogstraten's legal team of Peter Kelson QC and Dr David Thomas, states four grounds for challenging his conviction.

The document also states they will seek to reduce his sentence to between three and five years if his conviction is not quashed.

Firstly, they claim the trial judge, Mr Justice Newman, should have advised the jury to acquit Hoogstraten of manslaughter if they believed he did not order his henchmen to kill Mr Raja.

Mr Newman directed the jury to find Hoogstraten guilty of manslaughter if they believed he ordered Croke and Knapp to harm, but not kill, Mr Raja.

Mr Kelson and Dr Thomas's submission states: "The first sentence is a simple misdirection.

"If the co-defendants, having been ordered by the appellant to frighten the deceased by threatening him with force, by assaulting him or kidnapping him or doing damage to his home, "went beyond" what the appellant had ordered and killed the deceased, the appellant would not be guilty of manslaughter."

Secondly, they claim they were not given the opportunity to defend a verdict of manslaughter and the trial was therefore unfair.

The submission states: "No mention of a possible verdict of manslaughter was made until after all the evidence had been heard and speeches were about to begin."

It later goes on: "The prosecution case and defence case had been run from start to finish on the basis that the jury would be concerned with murder or conspiracy to murder."

Thirdly, they argue the case against Hoogstraten should have been thrown out of court after the close of the Crown's case.

The dossier states: "The case should have been stopped at the close of the Crown's case because the Crown's case amounted to nothing more than speculation informed by guilt by association."

In their final challenge, the lawyers state the evidence of Rizvan and Waheed Raja should not have been admitted.

The pair claimed their grandfather told them "these are Van Hoogstraten's men" shortly after the attack. This, they claim in their submission, should have been disregarded "by reason of being an opinion, or belief" rather than a fact.

Mr Kelson and Dr Thomas claim, because the jury accepted their client did not intend for Mr Raja to be killed, he bears minimal responsibility for the death.

They claim his sentence was, therefore, "manifestly excessive in all of the circumstances of the case" and should be reduced to three to five years.

The Crown Prosecution Service has refused to say if it will challenge the appeal.