A ground of opposition (in this case Article 100(c) EPC) introduced by an opposition division under Article 114(1) EPC must be prima facie highly relevant. Given that, firstly, a previous board of appeal had expressly stated that the amendments were supported by the application as originally filed, and secondly, it is plausible from the application as a whole that the amendments are disclosed, it cannot be said that the allegations under Article 100(c) EPC are prima facie highly relevant. In these circumstances introduction of the new ground by the opposition division amounts to a serious procedural violation justifying reimbursement of the appeal fee.