The report and the instruction trail
Dennis Venn FRICS, Vickery Holman, 23 June 2025, reference DV/113701. References below use physical pages of the reviewed 743-page June trial bundle.
- pp. 199–200: 23 May 2025 order authorising claimant-only instruction after strikeout, with questions permitted from either party.
- pp. 285, 287: instruction and inspection account; §4.1.2 distinguishes invoices and a poles/stays plan from agreements not supplied.
- p. 292, §5.4.5: asserted wayleave benefits and rents used in the boundary reasoning.
- pp. 295–298: instruction enclosures include a defendant-disclosed conveyance plan; the 30 May letter expressly mentions Miss E’s one-pole agreement.
- p. 392: Appendix IV plan visually matches the 28 April 2025 Shackson plan. The exact transmission and file provenance remain questions.
The report records a brief conversation with Miss E, no access to Lower Barley Hayes and inspection from the claimant’s land/public areas. Venn’s 11 July 2025 answers include the explanation that some bank positions were approximate without access. The nine submitted questions were the claimant’s, signed by Jack Christopher Kelsey Webb (professionally Jack Webb; barrister, 3PB, Bristol; called to the Bar in 2016). Miss E’s 13 July objection disclaims responsibility for those questions and costs; the reviewed record does not establish that she authored them.
R4 · 13 January 2026 · 8 pages
Supplementary Rebuttal to Claimant’s Newly Supplied Boundary Plan and Expert Mapping. Signed by Mr J. All pages were reviewed. Its nine numbered sections challenge the title comparison, fence-based reconstruction, utility evidence, expert inputs and further costs. Read the nine-part issue guide →
R5 · 13 January 2026 · 7 pages
Forensic Analysis and Justification to Exclude the Expert Report of Mr Dennis Venn FRICS (CPR 35 Non-Compliance and Evidential Contamination). Signed by Mr J. All pages were reviewed. Part A has seven substantive topics; Part B restates them and the requested protection from further expert expenditure. The public guide distinguishes those submissions from the report and order they challenge.
Original January attachments and court receipt
The original Sent email of 16 January 2026, 17:07 UK time contains nine attachments, including R4, R5, the 13-page January Annex E and the 12-page National grid documentation 2. R4 and R5 match the trial-folder copies byte for byte. The covering letter identifies the hearing on 19 January 2026.
The utility appendix’s physical pp. 7–9 reproduce Miss E’s executed agreement and signed plan; pp. 10–12 contain the intermediary’s letters. January Annex E section D, pp. 3–7, expressly alleges knowing withholding of executed documents already served on Seldons. That is the allegation in the January version, not a later February text substituted for it.
The email and later WeTransfer dispatch show attempted delivery. A court reply records missing files, including R4 and Annex E; resends followed on 19 January. The 18 January download notice does not identify the downloader. These records do not prove that every attachment reached or was read by the judge.
The earlier defence and executed agreement
PD1: the reviewed 43-page primary defence copy has a 3 August 2024 footer. Pages 12–13 put the Land Registry comparison beside National Grid plan 83920/SI, dated 28 March 2024. The reproduced plan’s signature field is blank in PD1; the executed copy is a separate record. Mr J says PD1 was supplied before the first hearing before Offen. Its printed date alone does not establish Seldons’ receipt date.
Executed documents: the trial bundle at pp. 133–136 lists and reproduces the agreement and signed plan with the March 2025 amended defence. The agreement is signed 4 June and countersigned 29 June 2024, with a 14-year term and £2,000 one-off payment. The plan labels BH68 and transformer 35-2381-1. The family identifies the adjacent physical line as the stock fence; the plan itself does not label that fence.
Inspect the published agreement comparison → · See the published plan →
The related correspondence
The attributed April 2024 Skea exchange predates Miss E’s June execution. Cornwell’s 31 January 2025 self-forwarded copy is separately examined for provenance. Shackson’s 13 March 2025 acknowledgment precedes his 28 April plan email; his 10 February 2026 reply describes a general area, not a particular title. His later explanation therefore postdates Venn’s June report.
Historic 1963/1975 agreements were supplied in November 2025. The question is their application to the specific land and poles, and what Venn actually had in June—not a claim that no utility agreement was ever produced. Read the transfer chain →
Download the Shackson and Skea letters before action and sent evidence packs → · Read the post-hearing disclosure record →
Read the connected investigation →
Mitchell’s direction and Venn’s interpretation
Trial bundle pp. 199–200: 23 May 2025 order, paragraphs 1–4. Notice, recorded strikeout, replacement of joint instruction, appended instructions and either-party questions are visible on the two-page order. p. 404: continuation of Venn’s July answer 4 refers to the restriction on representations. The distinction between original instruction, supplying facts and subsequent clarification questions needs the precise directions and hearing record.
Her refusal, the email wording and the costs submission
C’s Costs Submissions Exhibits, eight pages, pp. 4–5: Miss E’s 13 July 2025 objection reproduces Venn’s 11 July covering email. She denies asking questions, says she will submit none, and explains her objection to instructions and evidence received without her input. She disputes the process’s legitimacy and impartiality and fears her inclusion could be used to attribute questions or costs to her. These are her contemporaneous allegations and stated reasons.
The quoted covering email refers to “the questions put to me”, not “your questions”. It contains no payment demand. The trial-bundle question and answer covers at pp. 397 and 401 identify the claimant’s questions. A joint salutation and copying a party are not, by themselves, proof that the party asked questions.
The separate two-page Costs Submissions re Hearing 14 October 2025, filed with the 21 October email, p. 2, §5(d), expressly says Miss E declined to ask questions, citing exhibits pp. 4–5. It uses that fact against her procedural complaint within the claimant’s argument for indemnity costs. It is not evidence that Cornwell claimed she authored those questions. Any allegation of an actual fee attributed to her requires the corresponding request, invoice or assessment item.
The 23 May order, bundle pp. 199–200, permits questions from either party; Venn’s July answer 4, pp. 403–404, discusses a restriction on representations. Original instruction, material evidence, brief site contact, later questions and acceptance of the report must be distinguished. Read the comparison and named questions →
Public complaint source
Trustpilot: review and firm response · Dated summary and question
25 June 2026: the access and accuracy challenge
Original email: Mr J to Plymouth Court, copied to Miss E, Cornwell and Mayo. Body heading: “Response concerning proposed further Mr Venn plan, access and unresolved wayleave evidence”. The full chain was reread in Outlook on 25 September 2026, including the quoted Cornwell message and Mr J’s 26 June forward to counsel.
Cornwell’s message reports that Venn needed access for the additional hedge-centreline plan; it is not a Venn-authored email. Mr J’s section “Effect of the present access request” challenges the precision of the earlier drawings and expressly says lack of access alone does not prove every drawing false. His reply asks that the email be placed before Walsh before judgment. The dispatch establishes that the challenge was sent, not that Walsh personally read it.
Comparison references: trial bundle p. 287, report §4.1.8 (no access); p. 289, §5.1.9 (mapping not precise); p. 290, §§5.1.10 and 5.2.3 (best fit, top/bottom uncertainty and visual assessment); p. 407, July answer 8 (approximate bank positions and lack of plotting). The hedge-centreline task and bank-boundary opinions are distinguished in the article.
The reply also reports that Venn did not attend for scheduled cross-examination. That attendance account still requires the trial schedule and hearing record. It is not used here as a verified finding. Return to the comparison and named questions →