Unlawful Charging Order Dispute

please check all is in order: **WITNESS STATEMENT OF GARY JOHN TAYLOR** *. **Introduction**: - I, Gary John Taylor, of The Moorings, High Street, Barnby Dun, Doncaster, DN3 1DY, make this Statement of Claim Against The City of Doncaster Council and Its Representatives: Scot Robert Fawcus, Miss Emily Lewin, Alan Stoves, and Damian Francis Allen (in their personal capacities). *. **Core Issues**: - Unlawful Interim Charging Order - Procedural Breaches - Discrimination - Void Orders - Misrepresentation of LGFA * *. **Dwelling-House Definition and Classification**: - A "Dwelling-House" is a legally recognized ‘home’ with essential living facilities. This classification provides legal protections that the council's charging order disregards. The cases *Uratemp Ventures Ltd v. Collins [*] UKHL ** (Exhibit-GJT1) and *R (on the application of Wilson) v. Coventry City Council [*] EWHC * (Admin)* (Exhibit-GJT2) emphasize the need to protect residents from unjust housing policies. These protections are further reinforced by *Halsbury's Laws of England, Volume * (4th edition), Paragraph **. (Exhibit-GJT22) *. **Events and Personal Impact**: "On * November *, I was distressed to receive a notification of an interim charging order, retroactively dated * October * (Exhibit GJT19), issued by the council. This order was based on a bulk liability list attached to the reverse side of the order (Exhibit GJT21) included in a letter sent on * October * (Exhibit GJT20). The served copy of the interim charging order was received on * November *." "I formally reject the Claimant's unlawful attempt to impose a charging order on my residence, which is classified as a 'Dwelling-House' under *Halsbury's Laws* (Exhibit GJT22). This classification grants it significant legal protections, distinct from the term 'dwelling' used in the Local Government Finance Act *. This legal distinction directly impacts the legitimacy and enforceability of the charging order, rendering it invalid." *. **Violation of Individual Case Assessment**: - The processing of liability orders without individual court case reference numbers for each defendant undermines the need for individualized judicial scrutiny. This oversight contravenes the legal principles established in *R v. Birmingham Magistrates' Court ex parte Ahmed [*] EWHC Admin ** (Exhibit-GJT3). ***. Procedural Adherence and Fairness in Council Decisions**: - The case of *Regina v Horsham District Council [*] * W.L.R. ** (Exhibit GJT18) highlights the necessity for councils to follow proper procedures when making decisions. Here, the court upheld the council's decision to grant planning permission because correct procedures were followed, and all relevant factors were considered. This principle is equally crucial for property classification and the issuance of charging orders. The City of Doncaster Council must adhere to proper procedures and consider all relevant factors when classifying my property as a dwelling-house. Failure to do so undermines the legitimacy and fairness of their actions, as procedural compliance is a cornerstone of lawful and just decision-making. *. **Single Justice Procedure (SJP) Misapplication**: - Utilizing the Single Justice Procedure (SJP) for complex council tax disputes is inappropriate. These cases require detailed judicial scrutiny rather than summary handling under SJP, as highlighted in *R v. Birmingham Magistrates' Court ex parte Ahmed [*] EWHC Admin ** (Exhibit-GJT3). *. **Evidence Presented by the Claimant**: - The Claimant's documentation presents a Doncaster Magistrates Court Schedule of liability orders for council tax dated * July * for *,* defendants. Additionally, an impermissible 'liability order report' dated * July * on the reverse side evidences *,* defendants under illegitimate liability orders. The absence of lawful liability court orders and unique case numbers for * defendants across *, *, and * constitutes a severe breach of legal principles. This grave procedural error directly contravenes the established tenets in *R v. Swindon Borough Council ex parte Roberts [*] EWHC Admin ** (Exhibit-GJT4). *.** Discrepancy in Amounts Claimed and Lack of Supporting Evidence**: - The claimant's interim charging order lacks sufficient evidence to support the amount claimed on the N379. The Liability Order Report dated * July * specifies a total liability of £*,*.*, including liability, summons, and liability costs. However, the claimant's N379 form claims £*,*.* without adequate justification or adherence to proper procedures. This discrepancy highlights procedural deficiencies and insufficient supporting evidence for the interim charging order, as seen in cases like *Westminster City Council v. Haywood [*] EWHC * (Ch)* (Exhibit-GJT26) and *Lawson v. Serco Ltd [*] UKHL ** (Exhibit-GJT27). *. **Ramifications for Defendants**: - The mass processing of cases, lacking individual unique court claim identifiers and thorough judicial scrutiny of documents, leads to significant errors and injustices for defendants. This method strips individuals of their right to personalized legal scrutiny and a fair hearing, blatantly violating their legal, lawful, and human rights. *. **Petition for Judicial Review**: - I urge the court to scrutinize the procedural errors and misapplication of the Single Justice Procedure (SJP). Each defendant's case must receive thorough individual evaluation to ensure adherence to legal protocols, equitable treatment, and justice. *. **Dispute Regarding the Liability Order**: - I have made formal requests for detailed substantiating evidence from the Claimants about the alleged debts. To date, these requests remain unaddressed. This deficiency in evidence blatantly contravenes the findings in *Steel v. NRAM Ltd [*] UKSC ** (Exhibit-GJT5), which asserts that mere demands do not equate to definitive proof of debt. *. **Lack of Lawful Court Orders**: - The failure to issue lawful liability court orders and unique case numbers for * defendants across *, *, and * represents a severe violation of legal principles. This grave procedural error directly contravenes the established tenets in *R v. Swindon Borough Council ex parte Roberts [*] EWHC Admin ** (Exhibit-GJT4). *. **Violation of the Human Rights Act ***: - The Council's actions constitute a direct infringement of my rights under Article * of the Human Rights Act *, which safeguards an individual’s right to respect for private and family life. *. **Breach of the Disability Discrimination Act ***: - The actions taken by Doncaster Council may represent unlawful discrimination against me based on my health conditions, directly violating the provisions of the Disability Discrimination Act *. This Act mandates reasonable adjustments and unequivocally prohibits unfavourable treatment rooted in disability. Specific instances illustrate the council's failure to accommodate my health conditions, thereby breaching its obligations. *. **Contravention of the Equality Act ***: - **Indirect Discrimination**: - The Council's imposition of fines and additional financial burdens disproportionately impacts individuals with disabilities, breaching the principle of equal treatment, as established in *London Borough of Lewisham v. Malcolm [*] UKHL ** (Exhibit-GJT23). - **Neglect of Reasonable Adjustments**: - Despite my ongoing health issues that significantly compromise my financial standing, I have persistently made arrears payments when feasible. The Council has failed to adapt their approach or offer necessary support in light of my circumstances, violating their duty to implement reasonable adjustments as required under *Archibald v. Fife Council [*] UKHL ** (Exhibit-GJT24). - **Harassment**: - The Council has systematically targeted me by levying unnecessary costs at every turn over the years, even as I have attempted to resolve these issues amicably. This behaviour cultivates an environment of intimidation and hostility, amounting to harassment, as defined in *Majrowski v. Guy's and St Thomas' NHS Trust [*] UKHL ** (Exhibit-GJT25). *. **Void Court Orders**: - As stated by **Shirley Lewald**, a Solicitor Advocate with Higher Rights (Civil and Criminal Courts), a court 'ORDER' is void if issued without jurisdiction, in violation of the law, or in defiance of due process. This principle is supported by several case laws: - *Anlaby v. Praetorius* (*): A plaintiff cannot obtain a valid judgment if the proceedings are fundamentally void (Exhibit-GJT6). - *Crane v. Director of Public Prosecutions* [*]: An order void ab initio lacks the essential elements of a valid court order (Exhibit-GJT7). - *MacFoy v. United Africa Co. Ltd.* [*]: A void order is irrevocably void, rendering all proceedings founded on it void (Exhibit-GJT8). *. **Anticipated Rebuttals and Responses**: **Broad Interpretation**: The council might argue that the term "domestic property" in the * Local Government Finance Act covers all residential properties, including "Dwelling-Houses." However, *Uratemp Ventures Ltd v. Collins [*] UKHL ** (Exhibit-GJT1) establishes that "Dwelling-Houses" have a distinct legal status with specific protections. - **Legislative Intent**: They may claim that the legislative intent behind the Act was to create a uniform approach for all residential properties regarding council tax. This argument overlooks the elevated legal standards and protections mandated for "Dwelling-Houses" under *Halsbury's Laws of England*. - **Case Law Limitation**: The council could argue that case law distinctions apply only in specific contexts and do not universally exempt "Dwelling-Houses" from broader definitions in the Local Government Finance Act. The rulings in *Uratemp Ventures Ltd v. Collins [*] UKHL ** (Exhibit-GJT1) and *R (on the application of Wilson) v. Coventry City Council [*] EWHC * (Admin)* (Exhibit-GJT2) emphasize the necessity of individual judicial scrutiny and compliance with higher standards for "Dwelling-Houses." - **Procedural Compliance**: They might insist that their actions comply with procedural requirements outlined in the Act, regardless of the "Dwelling-House" classification. However, the failure to adhere to the stringent protocols required for "Dwelling-Houses" renders their actions procedurally deficient. - **Precedent Cases**: The council may present previous cases where similar arguments were unsuccessful, aiming to undermine my position. Nonetheless, the specific legal context and protections highlighted in *Uratemp Ventures Ltd v. Collins [*] UKHL ** (Exhibit-GJT1) and *R (on the application of Wilson) v. Coventry City Council [*] EWHC * (Admin)* (Exhibit-GJT2) are highly relevant to this case, reaffirming the necessity for adherence to elevated legal standards for "Dwelling-Houses." - **Legislative Intent**: They may claim that the legislative intent behind the Act was to create a uniform approach for all residential properties regarding council tax. This argument overlooks the elevated legal standards and protections mandated for "Dwelling-Houses" under *Halsbury's Laws of England*. - **Case Law Limitation**: The council could argue that case law distinctions apply only in specific contexts and do not universally exempt "Dwelling-Houses" from broader definitions in the Local Government Finance Act. The rulings in *Uratemp Ventures Ltd v. Collins [*] UKHL ** (Exhibit-GJT1) and *R (on the application of Wilson) v. Coventry City Council [*] EWHC * (Admin)* (Exhibit-GJT2) emphasize the necessity of individual judicial scrutiny and compliance with higher standards for "Dwelling-Houses."ns. *. **Reassessment of Property Classification in Light of Case Law**: - **Dwelling**: Defined for council tax purposes as properties intended or viable for residential use, as per the Local Government Finance Act * and supported by the ruling in *R (on the application of Wilson) v. Coventry City Council [*] EWHC * (Admin)* (Exhibit-GJT2). This classification includes council tax liability based on general residential suitability. - **Dwelling-House**: More narrowly defined as a 'home' equipped for day-to-day living, clarified in *Uratemp Ventures Ltd v. Collins [*] UKHL ** (Exhibit-GJT1). The implications influence council tax duties based on actual residential occupancy and available amenities. *. **Violation of the Human Rights Act ***: - The Council's actions constitute a direct infringement of my rights under Article * of the Human Rights Act *, which safeguards an individual’s right to respect for private and family life. - The improper classification of my property disregards my legal protections as a "Dwelling-House," undermining my right to a secure home environment. - The enforcement measures taken without recognizing these protections violate the principles of fairness and justice, further infringing upon my human rights. *. **Breach of the Disability Discrimination Act ***: - Doncaster Council's actions may constitute unlawful discrimination against me due to my health conditions, violating the *Disability Discrimination Act **. - The Act requires reasonable adjustments and prohibits unfavourable treatment based on disability. - Specific instances demonstrate the council's failure to accommodate my health conditions, breaching its legal obligations. *. **Contravention of the Equality Act ***: - **Indirect Discrimination**: The Council's imposition of fines and additional financial burdens disproportionately impacts individuals with disabilities, violating the principle of equal treatment. - **Neglect of Reasonable Adjustments**: Despite my ongoing health issues that significantly compromise my financial standing, I have persistently made arrears payments when feasible. The Council has failed to adapt their approach or offer necessary support in light of my circumstances, violating their duty to implement reasonable adjustments. - **Harassment**: The Council has systematically targeted me by levying unnecessary costs at every turn over the years, even as I have attempted to resolve these issues amicably. This behaviour cultivates an environment of intimidation and hostility, amounting to harassment. *. **Void Court Orders**: - As stated by **Shirley Lewald**, a Solicitor Advocate with Higher Rights (Civil and Criminal Courts), a court 'ORDER' is void if issued without jurisdiction, in violation of the law, or in defiance of due process. This principle is supported by several case laws: - *Anlaby v. Praetorius* (*): A plaintiff cannot obtain a valid judgment if the proceedings are fundamentally void (Exhibit-GJT6). - *Crane v. Director of Public Prosecutions* [*]: An order void ab initio lacks the essential elements of a valid court order (Exhibit-GJT7). - *MacFoy v. United Africa Co. Ltd.* [*]: A void order is irrevocably void, rendering all proceedings founded on it void (Exhibit-GJT8).   *. **Reassessment of Property Classification in Light of Case Law**: - **Dwelling**: Defined for council tax purposes as properties intended or viable for residential use, as per the Local Government Finance Act * and supported by the ruling in *R (on the application of Wilson) v. Coventry City Council [*] EWHC * (Admin)* (Exhibit-GJT2). This classification includes council tax liability based on general residential suitability. - **Dwelling-House** : More narrowly defined as a 'home' equipped for day-to-day living, clarified in *Uratemp Ventures Ltd v. Collins [*] UKHL ** (Exhibit-GJT1). The implications influence council tax duties based on actual residential occupancy and available amenities. *. **Violation of the Human Rights Act ***: - The Council's actions constitute a direct infringement of my rights under Article * of the Human Rights Act *, which safeguards an individual’s right to respect for private and family life. - The improper classification of my property disregards my legal protections as a "Dwelling-House," undermining my right to a secure home environment. - The enforcement measures taken without recognizing these protections violate the principles of fairness and justice, further infringing upon my human rights. *. **Breach of the Disability Discrimination Act ***: - Doncaster Council's actions may constitute unlawful discrimination against me due to my health conditions, violating the *Disability Discrimination Act **. - The Act requires reasonable adjustments and prohibits unfavourable treatment based on disability. - Specific instances demonstrate the council's failure to accommodate my health conditions, breaching its legal obligations. *. **Contravention of the Equality Act ***: - **Indirect Discrimination**: The Council's imposition of fines and additional financial burdens disproportionately impacts individuals with disabilities, violating the principle of equal treatment. - **Neglect of Reasonable Adjustments**: Despite my ongoing health issues that significantly compromise my financial standing, I have persistently made arrears payments when feasible. The Council has failed to adapt their approach or offer necessary support in light of my circumstances, violating their duty to implement reasonable adjustments. - **Harassment**: The Council has systematically targeted me by levying unnecessary costs at every turn over the years, even as I have attempted to resolve these issues amicably. This behaviour cultivates an environment of intimidation and hostility, amounting to harassment. *. **Void Court Orders**: - As stated by **Shirley Lewald**, a Solicitor Advocate with Higher Rights (Civil and Criminal Courts), a court 'ORDER' is void if issued without jurisdiction, in violation of the law, or in defiance of due process. This principle is supported by several case laws *. **Claim for Damages and Remedies**: - I claim substantial remedies and compensation for the significant damages caused by the actions of the City of Doncaster Council and its officials, specifically Scot Robert Fawcus, Miss Emily Lewin, Alan Stoves, and Damian Francis Allen (in their personal capacities). - **Financial Losses**: Compensation for fines and additional costs, totaling approximately £*,*. - **Emotional Distress**: I seek £*,* in compensation for severe emotional distress and mental health impact, reflecting the chronic nature of the distress endured. - **Layman's Fees**: As a litigant in person, I claim reimbursement for layman's services rendered in defending against the interim charging order and extensive correspondence over several years. This is calculated at £* per hour, totaling an estimated £*,*. - **Council Tax Reimbursement**: Full reimbursement of all council tax payments made under the incorrect classification of my property over the past 28 years, projected at £*,*, pending Council confirmation notwithstanding the typical six-year limit. *. **Continual Mistake and Classification Error**: - **Continual Mistake**: Overpayment of council tax due to the continual misclassification of my property as a "Dwelling" rather than a "Dwelling-House" has resulted in incorrect charges for 28 years. - **Legal Precedent**: *Gravesham Borough Council v Secretary of State for the Environment* [*] * P&CR * (Exhibit-GJT9) establishes that a "Dwelling-House" establishes that a "Dwelling-House" is defined by factual characteristics, including: - Essential living facilities (e.g., kitchen, bathroom, sleeping areas). - Physical structure and layout suitable for residential use. - Actual or intended use for residential purposes. My property fulfils these criteria and should be classified accordingly. The LGFA * lacks explicit provisions for such classification. - **Implication**: The absence of provisions for "Dwelling-House" in the LGFA * makes the council's billing legally questionable, undermining the lawfulness of the charges on my property. - **Legal Uncertainty**: The absence of a clear definition in the LGFA * creates ambiguity, leading to potential misclassification and unlawful charges on my property. - **Judicial Precedent**: *Uratemp Ventures Ltd v. Collins* [*] UKHL * (Exhibit-GJT1) emphasizes the legal distinction and protections afforded to properties correctly classified as "Dwelling-Houses." *. **Request for Evidence and Procedural Review**: - **Transparency and Fair Hearing**: Liability orders must be issued in open court to ensure transparency and accountability. Closed hearings ("star chambers") may undermine procedural fairness, violating Article * of the Human Rights Act *. This could result in the invalidation of the orders due to the lack of transparency. *R (on the application of Mackay) v. Newham London Borough Council* [*] EWHC * (Admin) (Exhibit-GJT10) highlights the importance of open hearings to uphold procedural fairness. - **Legal Requirements**: The issuance of liability orders must comply with the Local Government Finance Act * and other relevant regulations, proving my property is indeed a 'Dwelling-House,' lawfully liable for council tax under the LGFA *. - **Request for Information**: I request the court to demand: *. Evidence of the venue used for issuing the alleged lawful liability orders. *. Evidence of the documentation laid before the court. *. Evidence of the individual Court, unique case numbers with listings dates. *. Evidence that the Civil Business Centre is a lawful venue to issue an Interim Charging Order. - **Challenge Process**: If closed hearings were used, I challenge the validity of these orders based on the right to a fair and public hearing. *. **Comparative Case Studies**: - **Case *: * *Smith v. Northumberland County Council* [*] EWHC * (Admin)** (Exhibit-GJT11): - The court confirmed Smith's property, with essential living facilities, as a 'Dwelling-House,' granting it specific legal protections under housing laws. - **Case *: * *Brown v. Southwark Borough Council* [*] EWCA Civ *** (Exhibit-GJT12): - The court ruled in Brown's favour, recognizing the property met 'Dwelling-House' criteria due to essential living facilities, distinguishing it from a general 'dwelling' under the LGFA *. - **Case *: *Taylor v. Leeds City Council* [*] EWCA Civ *** (Exhibit-GJT13): - Taylor successfully argued for 'Dwelling-House' classification based on essential living facilities, with the court acknowledging the legal protections of this classification under housing laws. *. **Successful Challenges and Refunds**: -**Case *: *Williams v. Horsham District Council* [*] EWCA Civ *** (Exhibit-GJT14): - Williams successfully argued that his property was misclassified, leading to a refund of the overpaid council tax. - **Case *: *Jones v. Liverpool City Council* [*] EWHC * (Admin)** (Exhibit-GJT15): - Jones received a council tax refund after proving that his property was incorrectly classified as a 'dwelling' rather than a 'Dwelling-House'. - **Case *: *Smith v. Northumberland County Council* [*] EWHC * (Admin)** (Exhibit-GJT11): - Smith received a full refund of council tax payments due to incorrect property classification. *. **Conclusion**: - Given the multitude of procedural violations, discriminatory practices, breaches of the Equality Act *, improper application of the Single Justice Procedure, the presence of unlawfully issued liability orders from bulk listings, and the unjust issuance of the interim charging order by the Civil National Business Centre, I respectfully implore the court to: - Nullify the interim charging order. - Reimburse legal expenses and council tax payments. - Acknowledge and rectify procedural violations and instances of harassment. - Provide adequate compensation for financial losses and emotional distress caused. **List of Exhibits & Descriptions** *. **Exhibit-GJT1: Uratemp Ventures Ltd v. Collins [*] UKHL *** - Description: Legal case establishing the distinct legal status and protections for "Dwelling-Houses". https://publications.parliament.uk/pa/ld200102/ldjudgmt/jd011011/uratem-*.htm *. **Exhibit-GJT2: (R on the application of Wilson v. Coventry City Council [*] EWHC * (Admin)** - Description: Case emphasizing the importance of individual judicial scrutiny and compliance with higher standards for "Dwelling-Houses". https://vlex.co.uk/vid/r-wilson-and-others-* *. **Exhibit-GJT3: R v. Birmingham Magistrates' Court ex parte Ahmed [*] EWHC Admin *** - Description: Case highlighting the necessity of individualized judicial scrutiny in the processing of liability orders. https://vlex.co.uk/vid/r-v-the-birmingham-* *. **Exhibit-GJT4: R v. Swindon Borough Council ex parte Roberts [*] EWHC Admin *** - Description: Case The court examined the legality of the council's actions and the application of relevant laws in the context of administrative decisions emphasizing the requirement for lawful liability court orders with unique case numbers. https://duckduckgo.com/?q=R+v.+Swindon+Borough+Council+ex+parte+Roberts+%5B1997%5D+EWHC+Admin+*&ia=web *. **Exhibit-GJT5: Steel v. NRAM Ltd [*] UKSC *** - Description: Case asserting that mere demands do not equate to definitive proof of debt. https://www.supremecourt.uk/cases/docs/uksc-*-*-judgment.pdf *. **Exhibit-GJT6: Anlaby v. Praetorius (*)** - Description: Principle that a plaintiff cannot obtain a valid judgment if the proceedings are fundamentally void. https://www.iclr.co.uk/document/*/casereport_45719/html *. **Exhibit-GJT7: Crane v. Director of Public Prosecutions [*]** - Description: Case establishing that an order void ab initio lacks the essential elements of a valid court order. https://www.coursehero.com/file/*/Crane-v-Director-of-Public-Prosecutions-1921rtf/ *. **Exhibit-GJT8: MacFoy v. United Africa Co. Ltd. [*]** - Description: Case asserting that a void order is irrevocably void, rendering all proceedings founded on it void. https://vlex.co.uk/vid/macfoy-v-united-africa-* *. **Exhibit-GJT9: Gravesham Borough Council v Secretary of State for the Environment [*] * P&CR *** a "Dwelling-House" is defined by factual characteristics, which include: - Essential living facilities (e.g., kitchen, bathroom, sleeping areas). - Physical structure and layout suitable for residential use. - Actual or intended use for residential purposes. My property meets these criteria and should be classified accordingly. The LGFA * lacks explicit provisions for such classification. https://portal.peakdistrict.gov.uk/system/download/f/46366a62622b464337644779517061766661756a52413d3d *. **Exhibit-GJT10: R (on the application of Mackay) v. Newham London Borough Council [*] EWHC * (Admin)** - Description: Case highlighting the importance of open hearings to uphold procedural fairness. https://lawprof.co/public-law/legitimate-expectations-cases/r-bibi-v-newham-lbc-*-*-wlr-*/ *. **Exhibit-GJT11: Smith v. Northumberland County Council [*] EWHC * (Admin)** - Description: Case confirming the classification of properties with essential living facilities as 'Dwelling-Houses' with specific legal protections. https://uk.practicallaw.thomsonreuters.com/D-*-*?transitionType=Default&contextData=(sc.Default)&firstPage=true *. **Exhibit-GJT12: Brown v. Southwark Borough Council [*] EWCA Civ *** - Description: Case recognizing the property met 'Dwelling-House' criteria due to essential living facilities. *. **Exhibit-GJT13: Taylor v. Leeds City Council [*] EWCA Civ *** - Description: Case where the court acknowledged the legal protections of 'Dwelling-House' classification. *. **Exhibit-GJT14: Williams v. Horsham District Council [*] EWCA Civ *** - Description: Case where Williams successfully argued misclassification leading to a council tax refund. - https://vlex.co.uk/vid/r-williams-v-horsham-* *. **Exhibit-GJT15: Jones v. Liverpool City Council [*] EWHC * (Admin)** - Description: Case where Jones received a council tax refund after proving incorrect property classification. *. **Exhibit-GJT16: Shirley Lewald, Solicitor Advocate** - Description: Statement supporting that a court order is void if issued without jurisdiction, violating the law, or defying due process. *. **Exhibit-GJT17: Halsbury's Laws of England** - Description: Legal reference emphasizing the distinction between "Dwelling-House" and "dwelling" under housing laws and their respective protections. *. **Exhibit-GJT18: Regina v. Horsham District Council [*] * W.L.R. *** - Description: Legal case emphasizing the necessity for councils to adhere to proper procedures in decision-making. https://vlex.co.uk/vid/regina-v-horsham-district-* *. **Exhibit-GJT19: interim charging order, retroactively dated * October * *. **Exhibit-GJT20: - Description: Served copy of the interim charging order *. **Exhibit-GJT21: - Description: Liability Order Report dated * July * attached to reverse side the Order dated * July * *. **Exhibit-GJT22: - Description: *Halsbury's Laws of England, Volume * (4th edition), Paragraph ***. * **Exhibit-GJT23: Description: London Borough of Lewisham v. Malcolm [*] UKHL ***: - Description: This case addresses indirect discrimination under the Disability Discrimination Act *, establishing principles for the treatment of individuals with disabilities. https://www.casemine.com/judgement/uk/5a8ff70260d03e7f57ea5989 *. **Exhibit-GJT24: Description: Archibald v. Fife Council [*] UKHL ***: - Description: This case emphasizes the duty of employers and public bodies to make reasonable adjustments for individuals with disabilities, thereby preventing discrimination. https://www.casemine.com/judgement/uk/5a8ff70260d03e7f57ea5935 *. **Exhibit-GJT25: Description: Majrowski v. Guy's and St Thomas' NHS Trust [*] UKHL ***: - Description: This case defines harassment under the Protection from Harassment Act *, establishing that employers can be vicariously liable for harassment by their employees. https://publications.parliament.uk/pa/ld200506/ldjudgmt/jd060712/majro.pdf Exhibit-GJT26: - Description: Review of relevant case law "Westminster City Council v. Haywood [*] EWHC * (Ch)" highlighting procedural deficiencies. Exhibit-GJT27: - Description: Review of relevant case law "Lawson v. Serco Ltd [*] UKHL *" discussing procedural deficiencies. Exhibit-GJT28: - Description: Documentation of discrepancies and lack of evidence in support of the interim charging order. **Statement of Truth** I, Gary John Taylor, believe that the facts stated in this witness statement are true. Signed: __________ Date: * November

higligh the above points

are the url links acceptable as a exhibit reference instead of printing all the case law

it would make the file massive

check the summaries i have included

i was going to attach exhibits, *, *, and *, as all the other exhibits are caselaw, is this correct

will this then be complete ready for submission

any point need addressing in respect of *-* above

do all the exhibit descriptions contain enough information, if not rewrite the list for me to add

continue from, *. **Ex

continue, *. **Exhibit-GJT4: R v. Swindon Borough Council ex parte Roberts [*] EWHC Admin *** - Description: Case emphasizing the requirement for lawful liability court orders with unique case numbers. - URL: https://duckduckgo.com/

continue, *. **Exhibit-GJT8: MacFoy v. United Africa Co. Ltd. [*]** - Description: Case asserting that a void order is irrev

continue, *. **Exhibit-GJT10: R (on the application of Mackay) v. Newham London Borough Council [*] EWHC * (Admin)** - Description: Case highlighting the importance of open hearings to uphold procedural fairness. - URL: https://lawprof.co/public-law/legitimate-expectations-cases/r-bibi

continue, - URL: https://uk.practicallaw.thomsonreuters.com/D-*-*

continue, *. **Exhibit-GJT17

continue, *. **Exhibit-GJT23

continue, *. **Exhibit-GJT26: Westminster City Council v. Haywood [*] EWHC

is this correct, *. **Ramifications for Defendants**: - The mass processing of cases, lacking individual unique court claim identifiers and thorough judicial scrutiny of documents, leads to significant errors and injustices for defendants. This method strips individuals of their right to personalized legal scrutiny and a fair hearing, blatantly violating their legal, lawful, and human rights.