The allegation and the answer sought
Miss E and Mr J allege that material noise, dispute and conveyance-compliance problems were withheld before the sale. They say disclosure would have stopped the purchase and avoided the resulting loss. The Jenkins deny the allegations; their 15 July 2025 reply and the relevant pre-sale disclosures are linked alongside the challenge.
What did you know before the sale, what did you tell the buyer, and which records substantiate your answers?
Read the full investigation · Letter before action and reply · Source record
Direct questions
SELL-01
Who stands behind the pre-sale answers?
Identify who completed, checked and approved the Property Information Questionnaire dated 9 May 2023. Produce the complete final TA6, attachments, replies to enquiries and any corrections supplied before exchange. Which answers did each seller personally adopt?
SELL-02
What was known about shooting before the sale?
How was “No” to excessive noise or disturbance justified? Identify each seller’s knowledge of organised shooting before sale, frequency, proximity and complaints. Miss E recalls Rosalind saying at trial that there was little shooting when present, and reports David Daniels describing earlier shoots of forty people. Reconcile the actual knowledge and observations with the 15 July 2025 reply, and identify which parts of her account you dispute.
SELL-03
Earlier disputes. Later interference. Reconcile your denial.
How do you reconcile your account of an absence of earlier problems with the original agent’s report as relayed by Miss E, the driver’s recollection recorded on 31 May 2025, and the September 2026 agent letters documenting deterrence and marketing withdrawal? Identify what each seller knew before purchase, explain the 15 July 2025 denial of prior disputes with Mark John Mayo (claimant in L00BP152; Higher Barley Hayes, Torrington area, Devon), and produce the original viewing notes, buyer feedback and seller–agent communications. Which parts of the earlier accounts do you dispute, and what records support your answer?
SELL-04
Why “No” to covenants, but “Yes” to shared access?
Explain the PIQ’s “No” answer to easements/covenants alongside its “Yes — SHARED ACCESS” answer and the 2 June 1987 conveyance. What deed, plan and explanation of the rights and obligations were supplied to Miss E before exchange, by whom and when?
SELL-05
What compliance history was disclosed?
Identify the gate, shared boundary fencing, road and water obligations in the 1987 conveyance and the compliance history disclosed before sale. Miss E recalls evidence that the gate was never closed and alleges decades of unfulfilled obligations. Who installed and maintained the relevant structures, what complaints or agreements existed, and what deed, plan and explanation reached the buyer? Distinguish a requirement to install a gate from any continuing closing obligation under the instrument.
SELL-06
Why was the claimed stakes boundary not explained before purchase?
Where and when was the historic stakes line later supported by Rosalind June Jenkins (Former seller of Lower Barley Hayes; witness statement signed 14 March 2025) explained to Miss E before exchange? The PIQ Land entry refers to the Land Registry map; its separate Boundaries row is blank. Identify the precise stakes, when and by whom they were placed, the original conveyance and plan, and how that account fits the reported retained strip above the bank. Answer Miss E’s allegation that a materially different boundary account emerged only after purchase.
SELL-09
Where is the document-backed answer to the sale complaint?
Provide a point-by-point response to the 30 June 2025 letter before action, supported by the sale file and dated records. Address the alleged non-disclosures, Miss E’s statement that she would not have purchased, and the claimed financial and personal consequences. Identify any later substantive response and your position on a remedy.
SELL-10
Did you confirm a retained strip above the bank?
Miss E says Rosalind confirmed that her mother retained an upper area for plants, shrubs and maintenance access, and Peter described reaching it from the drive up a small bank. Did you give those descriptions? Identify the call date, words you accept or dispute, and the strip on a contemporaneous plan. How does it fit the later fence and stakes account, and what was disclosed before purchase?
SELL-11
What did the original viewing and marketing records reveal?
Miss E reports that the original selling agent later told her approximately 25 viewers attended during the Jenkins’ sale and that Mayo tried to discourage purchase. Produce the valuation, marketing, viewing-feedback and seller–agent records. What was reported to you, when, and what was disclosed before exchange? Identify the first valuation and sale instructions against the alleged 2018–19 changes next door.
SELL-14
What did your boundary representations lead the buyers to do?
Identify the boundary information supplied before exchange, the fencing-compliance history known to each seller and any disclosed stakes line. Separately address the post-purchase retained-strip telephone assurances described by Miss E. Which words do you accept, correct or dispute? Explain their consistency with the later testimony and answer the allegation that misleading information induced the purchase or reinforced the later fence challenge, causing avoidable expense and harm.
These consolidated publication questions are prepared for follow-up; the prior letter and reply have their own recorded dates.