No agreements supplied. Yet a boundary inference followed.
23 June 2025 / Report §4.1.2
What Venn says he lacked
“I have been provided with Western Power invoices but not copies of wayleaves agreements for either.”
He had requested agreements for Openreach and Western Power. He records receiving invoices and a poles/stays plan.
The same report / §5.4.5
What Venn nevertheless relied on
He treats asserted wayleave benefits and rent receipts for poles south of the stock fence as supporting the wall/bank boundary position.
Which contractual record justified that inference?
This is the material connection: the utility assertion was not merely background correspondence. It entered the reasoning about the disputed land. An invoice or apparatus map is not the missing agreement whose scope, parties and land could be examined. Source: report and instructions, trial bundle pp. 287, 292, 295–298 →
23 June 2025 → 25 June 2026 / The warning before judgment
An approximate survey. A further access request. What justified a precise boundary?
Mr J put this challenge to Plymouth Court on 25 June 2026, before judgment, copying Miss E, Luke Oliver Keith Cornwell and Mark John Mayo. His reply linked the inspection limits to the missing wayleave agreements and the R4/R5 objections. This was a dated request for those issues to be considered before the outcome—not a criticism first invented afterwards.
Original report / §5.2.3
The bank had not been measured
“I have not been able to measure the bank and have made a visual assessment only.”
Dennis Venn also identified uncertainty over whether the Ordnance Survey depiction represented the bank’s top or bottom, potentially making a 2–3 metre difference.
25 June 2026 / Cornwell to the court
The additional plan required access
“The Claimant’s expert witness (Mr Venn) has confirmed that he will need access to Lower Barley Hayes to produce this plan.”
Cornwell was reporting Venn’s position about an additional hedge-centreline plan, following the 10 June order.
- 23 June–11 July 2025: the report records no access to Lower Barley Hayes. July answer 8 describes approximate positions and says the precise bank top and bottom were not plotted owing to lack of access.
- 19–25 June 2026: Seldons requested access; consent was refused on 23 June. Cornwell told the court that Mayo had elected not to seek an access order before the scheduled 22 July handing-down hearing.
- 25 June 2026: Mr J asked that the response be placed before Timothy Edmund Walsh (Circuit Judge, Western Circuit; appointed to Exeter Law Courts on 27 June 2022). He challenged treating Venn’s drawings as precise and asked that neither refusal of voluntary access nor absence of the optional plan be used against the family.
The question is the weight given to known limitations. The earlier report already disclosed them; the later request reinforces them. Plotting the hedge centreline was also a different task from approximating bank boundaries. The issue is how those distinctions and uncertainties were resolved before deciding the disputed line.
Why this matters to the alleged property-taking sequence
Mr J alleges that Mayo, Cornwell, Seldons and Venn advanced a misleading evidential foundation to obtain land, linked to the disputed Nick Shackson plan and Amelia Skea email. He alleges judicial bias and collusion in the treatment of the family’s challenges. The connected documentary questions are concrete: the primary agreements were missing from the expert’s material; asserted utility rights nevertheless supported his boundary opinion; some relevant features had not been precisely surveyed; and the family asked for those issues to be addressed before judgment.
A vulnerable person’s property should not turn on uncertainty treated as certainty. Those links identify the acts and decisions to investigate; they do not themselves establish shared dishonest intent. The test is what each person knew, supplied, represented and decided—and what the contemporaneous records show.
Venn: identify the measurements and limits → · Cornwell, Seldons and Mayo: explain the reliance and supply trail → · Walsh: identify how the challenge was resolved →
Read the dated source references → · Follow the National Grid connection →
26–28 July 2025 / Public complaint and acknowledgment
The firm was put on notice. What did it establish?
Miss E’s one-star Trustpilot review, “Serious Concerns About Conduct and Integrity”, was posted on 26 July 2025, with 17 June recorded as the experience date. It alleges one-sided evidence, exclusion and misleading implications about questions and fees.
Vickery Holman replied on 28 July 2025: Venn was away; the firm would examine the matter and respond more fully. Read the review and company reply →
Where is the documented outcome? No further response is displayed on the inspected review; any private follow-up needs checking. The firm and Venn are asked for the findings →
Read her express refusal, Venn’s wording and the later costs submission →
11–13 July 2025 / Questions, objection and the later costs argument
She objected. She did not ask the questions.
Miss E’s position was deliberate nonparticipation in the formal question process—not acceptance of the report. Her 13 July email says she had been denied input into the instructions and an opportunity to present her position and relevant documents. She rejected what she regarded as a one-sided process. Mr J says her refusal reflected her belief that the process was corrupt from the outset.
11 July / Venn’s actual words
A joint address—not an express attribution
“Please find enclosed the responses to the questions put to me.”
Dennis Venn addressed the email jointly to Cornwell and Miss E. It does not say “your questions”; the attached answers identify the claimant’s questions. The email does not demand payment.
13 July / Miss E’s express objection
“I have not asked you any questions”
“I will not be engaging with you further, nor will I be submitting any questions.”
She copied the courts to prevent her inclusion being presented as participation in the question process or a basis for charging her for it.
Miss E alleges that the joint address created a misleading appearance of involvement. Mr J alleges dishonesty by Venn and Luke Oliver Keith Cornwell in the handling and presentation of her position. The specific test is whether anyone subsequently attributed questions, instructions, agreement or fees to her contrary to her written objection.
The later submission must be read accurately. In the costs submissions sent on 21 October 2025, paragraph 5(d) expressly says: “In reality, D declined to ask questions”. It uses that refusal to challenge her complaint about being denied questions, within the claimant’s argument for indemnity costs. It does not claim that she asked the questions. The unresolved issue is how her reasons for refusal—and her separate complaint about the original evidence supplied—were addressed.
Receiving answers is not commissioning questions. Declining questions is not endorsing a report. Neither fact, by itself, answers her challenge to the fairness of the expert’s original instructions and evidential foundation. Venn, Cornwell and Seldons: identify how her position was represented →
The stakes were costs, not merely a salutation. Paragraph 5(d) calls her claim that she was denied the right to ask questions “blatantly untrue”, as part of the claimant’s case for indemnity costs. Those are the claimant’s submissions, not findings. The distinction that needs answering is between her available right to ask later questions and her complaint about how the report was instructed and what evidence it considered.
Article 6: what effective opportunity did she have?
Article 6(1) protects a fair hearing before an independent and impartial tribunal. The Court’s civil-case guide, §§463, 469–471 and 478, explains equality of arms: a genuine opportunity to present one’s case and evidence without substantial disadvantage, and to challenge expert evidence effectively. Courts regulate admissibility; fairness is assessed across the proceedings as a whole.
Here, the 23 May order allowed either party to ask questions; that opportunity must be distinguished from input into the original instructions and documents. The accountability question for Paul Mitchell (Designated Civil Judge for Cornwall, Devon and Dorset; Exeter Combined Court Centre) is what effective route existed to put Miss E’s material evidence before the expert or court, how her objection was determined, and how any restriction was justified. Her decision not to use the question procedure is part of that assessment, not a substitute for it. Read the specific fairness question → · Read the dated source references →
Her agreement was known. Where was the document assessed?
Seldons’ 30 May 2025 instruction letter expressly acknowledges Miss E’s National Grid wayleave for one pole. The family’s January Annex E alleges that Seldons already possessed her executed agreement and plan and deliberately withheld them from Venn. Those executed documents do not appear in the report’s listed inputs and appendices.
A mention of an agreement is not a substitute for examining it. Cornwell and Seldons are asked to identify the actual enclosures and later transmissions. Venn is asked whether he received plan 83920/SI and the signed contract, and where he reconciled them with his opinion.
The earlier PD1 already sets National Grid’s diagram alongside the title-plan comparison. Mr J says it was served before the first hearing; the original service record remains to be checked. Independently of that earlier account, the May instructions establish acknowledged awareness of her arrangement.
See Miss E’s plan and the stock-fence connection → · Dates and document references →
Follow the chain—not just the disputed email.
- Claimed entitlement. The attributed Skea exchange is relied on concerning Mayo’s BH67/BH68 position. The family seeks the original messages and operative agreements.
- The disputed copy. Cornwell self-forwarded the chain on 31 January 2025. The family alleges editing; the native messages and version history are needed to establish what changed.
- The apparent spatial support. Shackson sent a plan with “on your title” wording on 28 April 2025, after acknowledging Miss E’s documents in March. Appendix IV in Venn’s report visually matches that map. Its exact transmission to the expert needs to be identified.
- The expert inference. Venn’s June report links asserted pole arrangements and rents to the boundary, despite recording that the requested agreements were not supplied.
- The proposed legal consequence. The family says this lent expert authority to a claim affecting the bank and land. R4/R5 challenge the integrity of that foundation before further reliance and expense.
Shackson’s 10 February 2026 general-area explanation came later. It must be compared with what the expert was told in 2025, not placed before the report in the chronology. The report records a request for agreements; it does not identify a direct request to National Grid or establish who withheld a response.
Read the linked Shackson–Skea allegation → · Compare Shackson’s wording and replies → · Follow the self-forwarding and redaction challenge →
Paul Mitchell / Circuit Judge / 23 May 2025 direction
A procedural sanction does not answer a boundary question.
Mr J alleges that Paul Mitchell’s decision was deliberately biased, corrupt and part of collusion to advance Mayo’s claim over the family’s land. The challenge is specific: when the claimant controlled the instructions, what ensured that material evidence supporting Miss E was still assessed before an expert opinion was used against her?
What the order actually directed
Mitchell’s 23 May 2025 order, paragraphs 2–4, records that the defence and counterclaim stood struck out for non-compliance with the March unless order. On that basis it replaces the earlier joint instruction with claimant-only instruction of Venn. It requires the instruction letter to accompany the report and permits questions from either party.
What the expert later understood
In answer 4, dated 11 July 2025, Venn refers to a court direction preventing defendant representations and says the site conversation did not affect his boundary opinion. That raises a precise scope question: which direction, covering which stage and which material?
The order records Miss E’s complaint that she was not notified and the court’s finding that notice had been sent to solicitors then on the record on 7 May. The hearing proceeded without her. Identify the notice and hearing record and explain how her objection was determined.
Permission for sole instruction is not permission for selective fact-finding. Nor does it itself establish bias: Part 35 permits party-instructed experts. The issue is whether the process and report dealt properly with material contrary evidence. A right to ask later clarification questions does not, by itself, establish that the original inputs were complete.
Paul Mitchell: identify the reasons and safeguards → · Venn, Cornwell and Mitchell: identify the representation restriction → · Order and answer references →
Same proceedings / Distinct decisions / Connected allegation
Money demanded. Property contested. Show the foundations of both.
Mr J connects the expert direction to the earlier costs dispute: he alleges that financial pressure and a selectively informed boundary report served the same attempt to obtain control of the family’s property. He accuses Mitchell, Mayo and Cornwell of deliberate wrongdoing in that alleged sequence.
- March 2025: the costs sequence includes the 10 March directions and 21 March paper assessment of £1,750. The request is for the schedule, calculation and service record behind that assessment.
- 23 May–23 June 2025: Mitchell authorises claimant-only expert instruction; Seldons acknowledges Miss E’s wayleave in its instructions; Venn records missing utility agreements but draws a boundary inference from asserted arrangements.
- 17 March 2026: Seldons asserts service of the earlier N260 on 17 March 2025 at 15:37 but declines further documentation unless required.
- 19 August 2026: the later Blohm order refuses the application for N260 disclosure. The family challenges that refusal in the linked appeal record.
The family says the March 2025 N260 remains unprovided; this review has not located the original schedule or service email. Later hearing schedules are separate documents. Non-production does not establish that no schedule ever existed, and the expert direction does not establish the alleged criminal connection. The direct test is the contemporaneous record for each decision—not a repeated assertion that the outcome was justified.
Follow the assessment record → · Read the claimed service and refusal → · Follow the disclosure refusal → · The connected question to Mitchell, Cornwell and Seldons →
13 January 2026 / All distinct R4 and R5 challenges
Nine issues. Each tied to a source and an answer.
R4 challenges the newly supplied plan; R5 challenges Venn’s report. The overlapping points are consolidated here, with the separate mapping, physical-feature and costs objections retained.
01Disputed inputs and omitted executed documents
R4 p. 1, §8 (p. 6); R5 §1, Part B §§2–3
Mr J alleges that solicitor-curated, self-forwarded email material displaced Miss E’s executed National Grid evidence and left Venn with a one-sided factual basis. R4 itself says the exact supply and withholding history was not visible to the court.
The test: Produce the complete instructions, enclosures, later messages and versions. What did each person possess, supply, request and assess?
02A boundary opinion—or justification for a fence?
R4 §§2–3 (p. 3), §6 (p. 5); R5 §2 (p. 2), Part B §§4–5
The submissions allege reverse engineering: that the later mapping was shaped to support Mayo’s fence rather than independently establish the historic boundary.
The test: Show the route from the conveyances, measurements and historic features to the conclusion, without assuming the disputed fence is correct.
03Departure from the title-plan comparison
R4 §§1, 3, 5–7; R5 §3 and Part B §6
Mr J argues that the new geometry does not reconcile with the title documents and National Grid plan. His filings claim those plans have decisive priority.
The test: Identify the scale, tolerances, deed interpretation and evidence behind any different line. Registered title plans normally show general—not exact—boundaries; the discrepancy must be examined, not treated as self-proving.
04BH68 and the executed agreement
R4 §4 (p. 4); R5 §4 (pp. 3–4), Part B §7
The family says the pole beside the stock fence corroborates its boundary position and that the report does not reconcile that position with Miss E’s contract and signed plan. R4 §4 and R5 §4 specifically allege that BH68 was attributed to Mayo’s land without an identified deed, variation or registry change; they challenge the documentary basis for that attribution.
The test: Where did the report assess plan 83920/SI and the executed agreement? A utility agreement identifies contractual rights and apparatus; its boundary significance must be explained against the land evidence.
05£2,000 and £25: identify what each payment covered
R5 §4 (p. 4), Part B §8; January Annex E, section D
Mr J challenges the apparent competing payment accounts as evidence of an invented entitlement. The inspected agreement specifies a £2,000 one-off payment for a 14-year term; the disputed email concerns £25 annually for BH67 and BH68.
The test: Reconcile each agreement, apparatus schedule, land parcel and payment period. These are different payment structures, not an established like-for-like tariff or proof that concurrent arrangements were impossible.
06The “best fit” exercise
R5 §5 (pp. 4–5), Part B §9
Mr J challenges moved overlays and adjusted geometry, arguing that approximation has been used to support an outcome rather than test it.
The test: Disclose the source scales, control points, transformations, error margins and alternative alignments. Explain why the chosen method is reliable for the conclusion claimed.
07Was the bank physically altered?
R5 §6 (p. 5), Part B §10
The submissions allege that driveway widening and excavated material changed the bank, so a later physical feature was being treated as an historic boundary.
The test: Compare dated plans, photographs and works records. Which feature existed at the relevant conveyance date, and what evidence distinguishes it from subsequent works?
08Inspection limits and uncorroborated recollections
R5 §§1, 7 (pp. 1–2, 5), Part B §§2–3
Mr J challenges the lack of access to Lower Barley Hayes and reliance on Britton and footpath recollections. Venn records an initial tour with Mayo, subsequent inspection without him and brief contact with Miss E; his July answers acknowledge approximation where access was unavailable.
The test: Identify the documentary checks, the information Miss E supplied, the access sought and the qualifications warranted by incomplete measurements or uncertain recollection.
09Resolve the integrity objection before imposing further expert costs
R4 §§8–9 (pp. 6–8); R5 Part B §§11–12 (pp. 6–7)
The requested remedy was a threshold decision on reliability and admissibility before Miss E and Mr J were required to fund a responding expert. They describe further expenditure on allegedly contaminated evidence as oppressive.
The test: Identify how the court determined that request and the reasons given. This is the remedy the submissions sought, not a rule automatically suspending proceedings.
The objections were written down before the January hearing.
- 3 August 2024: the reviewed PD1 copy compares National Grid and title plans; original service timing remains to be verified.
- 23–30 May 2025: the court authorises claimant-only instruction; Seldons instructs Venn and acknowledges Miss E’s one-pole agreement.
- 17–23 June 2025: inspection and report. The requested agreements are recorded as unprovided.
- 11–13 July 2025: Venn’s answers to the claimant’s questions, followed by Miss E’s objection concerning participation and costs.
- 26–28 July 2025: public complaint and company acknowledgment; see the review record above.
- 13–16 January 2026: R4/R5 are dated 13 January and attached to Mr J’s 16 January email, alongside the January Annex E and executed National Grid documents.
- 19 January 2026: further emails resend material before the identified hearing. A court reply had recorded an incomplete receipt; sending must not be confused with proof of judicial reading.
- 10 February 2026: Shackson describes the plan as covering a general area, not a particular title.
What was actually determined about these specific objections? The family challenges the later judgment’s treatment of its evidence. The next step is to compare each objection with the hearing record and the precise reasons—not assume that a filed allegation was adjudicated merely because proceedings continued.
Original attachments and receipt detail → · Continue to the judgment challenge →
Part 35: test the evidence, not the preferred outcome.
One party may instruct an expert. Neither party owns the expert’s opinion. The 23 May order authorised claimant-only instruction; the question is how the report met the continuing duties below.
- Independence and adverse facts · PD35 2.1–2.4
- Opinions should be objective, not advocacy, and address material adverse facts and insufficient information. Where were Miss E’s executed agreement and plan assessed?
- Transparent foundations · CPR35.3 and 35.10 · PD35 3.2
- The court duty overrides the payer’s interest; material instructions, sources, assumptions and qualifications must be identified. Which facts supported §5.4.5 when §4.1.2 records missing agreements?
- Missing material · CJC guidance 20(d), 23, 30 and 55
- Instructions should include relevant disclosure; experts should seek relevant information, flag omissions and identify material received. Produce the dated supply trail and response to the agreement request.
- Testing and clarification · CPR35.6, 35.10(4) and 35.14
- Clarification questions and requests for directions provide routes to test the report. Specific instruction-document disclosure requires reasonable grounds for finding the stated instructions inaccurate or incomplete. What route addressed these omissions before further reliance?
These are document-specific tests, not a declaration that every criticism establishes a breach. The report records a defendant-disclosed conveyance plan, brief contact with Miss E and measurement limits. The issue is the significance of the particular missing evidence. Read Venn’s accountability record →
21 proposed questions / Not yet sent by this publication
Identify the document. Explain the omission. Answer the consequence.
VENN-01 / Dennis Venn FRICS
No agreements supplied. What justified the wayleave conclusion?
Your report §4.1.2 records that the requested Openreach and Western Power agreements were not provided. Section 5.4.5 nevertheless uses asserted wayleave benefits and rent receipts to support the boundary position. Identify the instrument, land, apparatus and verified fact supporting each step of that inference. Distinguish an invoice, an apparatus map and a contractual right.
VENN-02 / Luke Oliver Keith Cornwell · Seldons LLP
The instruction letter acknowledged Miss E’s agreement. Was it enclosed?
Your 30 May 2025 instructions mention Miss E’s National Grid agreement for one pole. When did you receive her executed agreement, signed plan 83920/SI and PD1 comparison? Identify each version and supply the complete enclosure list, transmission emails and subsequent exchanges with Venn. If her documents were not supplied, identify who made that decision and why.
VENN-03 / Dennis Venn FRICS
Where did you assess her executed agreement and signed plan?
Identify whether and when you received Miss E’s executed June 2024 agreement and signed plan 83920/SI. They do not appear in the reviewed list of inputs and appendices. If you received them, identify where you assessed them; if not, what did you do after being told of her agreement? Would those documents change or qualify your opinion, and why?
VENN-04 / National Grid Electricity Distribution (South West) plc · Nick Shackson
What exactly was sent in response to the request for agreements?
Identify any request you received from Venn or those instructing him, the recipient, date and complete response. What material supported the claimed BH67/BH68 entitlement and the map supplied on 28 April 2025? Was Miss E’s agreement and plan identified or supplied, and if not, why? The report establishes a request for agreements, but not who at National Grid received a direct request.
VENN-05 / Amelia Skea · National Grid Electricity Distribution (South West) plc · Luke Oliver Keith Cornwell
Authenticate the email before it is used to support a boundary claim.
Authenticate the original April 2024 exchange attributed to Amelia Skea and identify what agreements her reply concerned. Compare the native messages with the 31 January 2025 self-forwarded copy and every version supplied to Venn. Cornwell: identify any editing, the preserved original and what Venn was told about its provenance.
VENN-06 / Nick Shackson · Luke Oliver Keith Cornwell · Dennis Venn FRICS
Which plan reached the expert—and what was it said to prove?
Identify the date, sender and exact file supplied for Appendix IV. Its appearance matches the Shackson plan of 28 April 2025. Explain the title-specific wording accompanying that plan, its stated accuracy limits and the later general-area explanation. What title or ownership conclusion, if any, did each recipient draw from it?
VENN-07 / Dennis Venn FRICS
Show the method without assuming the disputed fence is correct.
R4 §§2–3 and R5 §§2–3 and 5 allege that the mapping rationalises Mayo’s existing fence. Identify the deed interpretation, historic features, survey measurements, overlay transformations and tolerances supporting your conclusion independently of that fence. Explain the alternatives you tested and any departure from the family’s title-plan comparison.
VENN-08 / Dennis Venn FRICS · Mark John Mayo
Was an altered bank treated as an historic boundary feature?
R5 §6 alleges that driveway widening and deposited material re-formed the bank. Identify the dated evidence of the bank’s position before and after those works, what Venn was told, and how the report distinguished historic features from later alterations. Mayo: identify the works, dates, plans and records supplied to the expert.
VENN-09 / Dennis Venn FRICS
What limits did inspection and recollection place on the conclusion?
Explain the effect of no access to Lower Barley Hayes, the brief conversation with Miss E and the information obtained from Mayo. Identify the contemporaneous support for the Britton and footpath recollections, the uncertainties you recognised and where they qualified the final opinion. Address your July explanation that some bank positions could only be approximate.
VENN-10 / Luke Oliver Keith Cornwell · Seldons LLP · Dennis Venn FRICS
When the integrity objections arrived, what did you check?
R4, R5 and the January Annex E alleged omission of known executed documents and manipulation of the expert’s inputs. Identify when each of you received those objections, what was checked and any correction, supplemental opinion or document-supported response. Seldons: name the person who reviewed the allegation against the firm separately from the allegation against Cornwell.
VENN-11 / Mark John Mayo · Luke Oliver Keith Cornwell
Where is the documentary route from the claimed pole rights to the claimed land?
Identify the contemporaneous deed, applicable wayleave, plan and transfer history supporting the boundary position advanced through Venn. Explain how they address Miss E’s executed agreement and historic account. Distinguish documents available to Venn in June 2025 from the historic agreements produced in November 2025.
VENN-12 / Solicitors Regulation Authority
Were known contrary documents withheld from the expert?
Will you assess the specific instruction and disclosure records identified in VENN-02, VENN-05 and VENN-10 against the duties not to mislead, misuse evidence or advance unsupported assertions, and the firm’s supervision duties? Identify the evidence reviewed and give reasons addressing those particulars, rather than treating the allegation as a disagreement with an expert alone.
VENN-13 / Vickery Holman Ltd · Dennis Venn FRICS
What did your promised review establish?
Vickery Holman: identify who conducted the review you announced on 28 July 2025, what evidence was checked and the dated outcome supplied to Miss E. Venn: identify your response and any correction or supplemental opinion. Explain separately the material considered, participation concerns and any fee actually charged or claimed.
VENN-14 / Paul Mitchell
Why remove joint instruction—and what protected the contrary evidence?
Your 23 May 2025 order replaced joint instruction with claimant-only instruction after recording strikeout. What reasons and safeguards ensured that a reliable boundary opinion would still address material documents supporting Miss E? Identify how her objection to notice of that hearing was resolved, what factual material the expert was to receive, and the route for challenging omissions without treating the disputed boundary as already proved.
VENN-15 / Dennis Venn FRICS · Luke Oliver Keith Cornwell · Paul Mitchell
Which direction prevented representations, and how did you apply it?
Venn’s 11 July 2025 answer 4 refers to a court direction preventing defendant representations; the 23 May order also permits questions from either party. Identify the exact direction and distinguish instruction, factual information and clarification questions. Venn and Cornwell: was any relevant material refused or omitted on that basis? Mitchell: what was the intended scope, and what procedure protected assessment of material contrary evidence?
VENN-16 / Paul Mitchell · Luke Oliver Keith Cornwell · Seldons LLP
Produce the foundations of both decisions—not one disputed outcome as an answer to the other.
Mitchell: identify the schedule, calculation and reasons supporting the 21 March 2025 £1,750 assessment, separately from the reasons and safeguards for the 23 May expert direction. Cornwell and Seldons: produce the original March costs schedule and service email you say exist, and the complete dated expert enclosure trail. The family alleges these decisions and omissions formed deliberate pressure supporting a property claim. Which contemporaneous records answer that allegation?
VENN-17 / Dennis Venn FRICS
Which boundary positions were measured—and which were estimates?
Your report §5.2.3 says the bank was assessed visually rather than measured; July answer 8 says its precise top and bottom were not plotted owing to lack of access. Cornwell’s 25 June 2026 email reports that you needed access for the additional hedge-centreline plan. Identify the measured and estimated positions, tolerances and independent checks in each drawing. What could the additional inspection establish that the first report could not, and what conclusions could safely be drawn without it?
VENN-18 / Luke Oliver Keith Cornwell · Seldons LLP · Mark John Mayo
What justified continued reliance after the limitations were challenged?
Identify the scope and degree of precision claimed for Venn’s plans in your submissions. Produce the correspondence behind the 25 June 2026 access statement and your document-supported response to Mr J’s reply. Where did you address the unmeasured bank, missing utility agreements and Miss E’s executed BH68 agreement and plan? Distinguish the additional hedge-centreline task from the original boundary opinion and identify what evidence resolved the remaining uncertainty.
VENN-19 / Timothy Edmund Walsh
Where were the pre-judgment objections resolved?
Mr J sent Plymouth Court a 25 June 2026 response asking that it be placed before you before judgment. Was it placed before you? Identify where the reasons address the expert’s visual assessment, approximate bank positions, missing wayleave instruments and request for access to produce a further hedge-centreline plan. If a precise disputed line was determined, what evidence and treatment of uncertainty justified it? Identify how the requested consideration of R4, R5 and Annex E was resolved.
VENN-20 / Dennis Venn FRICS · Luke Oliver Keith Cornwell · Seldons LLP
Was her express objection accurately represented?
Miss E’s 13 July 2025 email denied asking questions and said she would submit none because she disputed the process. Venn: explain the joint address and identify whose questions were answered and who was invoiced. Cornwell and Seldons: your October submission expressly says she declined questions; identify how you addressed her stated reasons and separate complaint about the original inputs. Did anyone represent her as commissioning questions, accepting the report or consenting to the process? Identify the exact communication and any fee attributed to her, or confirm that no such representation or charge was made.
VENN-21 / Paul Mitchell
What effective opportunity existed to present and challenge the evidence?
Your 23 May 2025 order allowed questions from either party after claimant-only instruction. Distinguish that later opportunity from supplying relevant documents and factual material for the original opinion. What effective route existed for Miss E to present her evidence and challenge the expert’s foundations? Identify the reasons for any restriction, safeguards against substantial disadvantage and determination of her stated objection. Explain how those matters, including her decision not to ask questions, were addressed consistently with Article 6 fairness.
Read the sources in order.
Report paragraphs, R4/R5 references, instructions and the January filing record →
Published National Grid letters and evidence packs → · Historic agreements and later disclosure →
Report and submission sources reviewed 25 September 2026. R4/R5 present Mr J’s challenges, not an independent determination of them. Material replies will be linked to the issue they answer.
The reporting record
What changed in this article.
- Source comparison · Participation and fairness
She objected. She did not ask the questions.
Miss E’s express refusal of 13 July 2025 is displayed beside Venn’s exact email and the later costs submission. Two further questions examine how her position was represented and what effective opportunity she had to present and challenge evidence.
Read her objection and the Article 6 fairness question - Dated source comparison · Pre-judgment challenge
The bank was not measured. What justified the disputed line?
The original survey limits, Cornwell’s later access statement and Mr J’s 25 June 2026 court reply now sit together. Three further questions to Venn, Cornwell, Seldons, Mayo and Timothy Edmund Walsh connect the missing agreements to the degree of precision claimed for the boundary evidence.
Read the comparison and pre-judgment warning - Updated strand · Expert evidence and judicial safeguards
The agreements were missing. The boundary opinion was not.
Nine R4/R5 challenges and sixteen named questions now connect the public complaint, Part 35 standards, Paul Mitchell’s direction and the separate costs-document dispute to the family’s alleged property-taking case.
Follow the evidence into the boundary report
Substantive additions and corrections will be recorded here. The full case can be followed through Latest developments.
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