Letter before action 26 sept 2019 r

Independent Office for Police Conduct
PO Box 473
Sale
M33 0BW
Grimsby
North East Lincolnshire
DN32
26 September 2019
Dear Ms Badham,
In the matter of a proposed application for judicial review between The Queen (on the
application of ) and INDEPENDENT OFFICE FOR POLICE
CONDUCT
Please find for your attention in the format recommended by the pre-action protocol for judicial
review, a letter before claim.
It is my preference that this matter be resolved without recourse to the courts if at all possible,
however, should it be necessary to issue proceedings, such proceedings will need to be dealt with
on an expedited basis given that a claim for judicial review must be filed promptly and in any
event, where no permission is granted for extension, not later than 3 months after the date of the
decision being challenged.
I look forward to receiving a response in due course and, in any event, by no later than Thursday,
10 October 2019. I take the date of decision being challenged to be 25 April 2019 (the decision
letter) and therefore consider that the statutory time limit within which I must bring a claim under
normal circumstances would be no later than 25 July 2019. I am of course aware that should the
matter be pursued an extension application would be required.
Yours Sincerely
.

1
IN THE MATTER OF A PROPOSED APPLICATION FOR
JUDICIAL REVIEW IN THE HIGH COURT OF JUSTICE
QUEEN’S BENCH DIVISION ADMINISTRATIVE COURT
BETWEEN:
THE QUEEN
(on the application of )
Proposed Claimant
-and-
INDEPENDENT OFFICE FOR POLICE CONDUCT
Proposed Defendant
JUDICIAL REVIEW PRE-ACTION PROTOCOL
LETTER BEFORE CLAIM
Information required in a letter before claim
I. Proposed claim for judicial review
To
The Independent Office for Police Conduct, PO Box 473, Sale, M33 0BW
II. The Claimant
of , Grimsby, North East Lincolnshire, DN32 .

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III. Defendant’s reference details
Present appeal ref: 2019/115969 (linked appeal ref: 2017/082079)
IV. Details of the legal advisers, if any, dealing with this claim
None.
V. Details of the matter being challenged
The decision of the Independent Office for Police Conduct (the ‘Proposed Defendant’) not to
review the findings of an investigation carried out by Humberside Police or direct that the
complaint be re-investigated.
VI. Details of any interested parties
None proposed. However, it is envisaged that a potentially significant number of people would
benefit from the issue being reviewed. Namely, those who would in similar circumstances to the
Proposed Claimant be affected by the Proposed Defendant’s powers being exercised to their
detriment.
VII. The issue
Background
1. The proposed claimant (‘PA’) was a victim of a miscarriage of justice which he believes was
the result of a malicious prosecution – the consequence of a stitch-up between Humberside
police, Grimsby Magistrates court and the Crown Prosecution Service. Despite all the
safeguards built into each stage of the criminal justice system, he was investigated,
prosecuted and found guilty of an offence he did not commit.
2. On 27 August 2015 PA was involved in an incident which led to him being arrested and
charged with an offence under s.5 of the Public Order Act 1986. Two members of the public
provided witness statements for the purposes of the criminal proceedings. PA believes that
the arresting officer had incited at least one of the witnesses to make a false statement and
that both witnesses had made false statements therefore committing perjury before the court.

3
3. A hearing in relation to the offence took place on 30 September 2015 at which PA pleaded
not guilty (he had formally confirmed earlier on 4 September that a ‘not guilty’ plea would be
entered at the first hearing). The court directed that PA was prohibited from cross-examining
the witness in person and arrangements made for a solicitor to do so at a further hearing listed
for 15 December 2015. PA submitted a complaint to Humberside Police on 8 November 2015
regarding the arresting officer, alleging he had incited the witnesses to give false accounts and
explicitly reported perjury in respect of their statements (he asked to be provided crime
numbers).
4. The complaint was formally recorded on 24 November 2015 and a copy of the record
enclosed in a letter of 1 December 2015 which explained that it is practice to suspend
investigation of the complaint until after the proceedings1
. Only the allegations against the
police were recorded (those against the witnesses were not) which prompted PA to write to
the force on 2 December and request that it also investigate his allegations that the two
members of the public had made false statements before the court. In its response of 3
December the force stated that the court was the correct forum to challenge the matter and
that it was not practice to investigate such allegations unless the magistrates or judge
recommended that the police do so2
, unless there were aggravating circumstances3
and it
would be considered an abuse of the complaints process if it investigated the allegation under
the Police complaints process as the situation stood4
.
5. PA subsequently forwarded his complaint about the arresting officer to the Court on 11
December 2015, together with an account stating that two members of the public had both
made untrue witness statements. The case went ahead in his absence during which he was
found guilty and convicted of an offence under s.5 of the Public Order Act 1986 and
sentenced on 22 December 2015. He did not attend the 15 December 2015 hearing, after
discovering which judge would be trying the case. He expressed without reservation in his 11
December correspondence that he did not consider the judge, ‘a fit and proper person to hear
1
An investigation may be suspended under Regulation 22 of the Police (Complaints and Misconduct) Regulations
2012 which would, if it were to continue, prejudice any criminal investigation or proceedings
2
This is contrary to the view of the CPS whose advice is that ‘where a judge or magistrate believes that some
evidence adduced at trial is perjured s/he can recommend that there should be a police investigation. The absence of
such recommendation does not mean that there is no justification for an investigation’.
3
Witness statements were false and other evidence was clearly unreliable, inconsistent and/or of questionable
credibility, so there were aggravating circumstance.
4
It was in fact the police who were abusing the complaints process by suspending the investigation of the police
conduct complaint for several reasons; one of which being that the alleged offence committed by the police was
more serious than the offence that the defendant was charged with.

4
the case’. This was on the basis that the judge presiding over the matter was the same judge
who had presided over a recent earlier case involving Council tax liability who had
unequivocally accepted a statement knowing it to be false5
. PA had as a consequence been
defrauded with an attached claim of costs (evidence of this had also been sent to the Court on
11 December). The judge sentencing on 22 December 2015 was clearly oblivious to the
proceedings as he responded to PA’s protest at being wrongly convicted that he had a chance
to put his side of the story at the trial but did no turn up (his side of the story was documented
in mitigating evidence which the court just did not bother to take into account).
6. The police wrote on 29 December 2015 to inform PA that the conduct complaint, which had
been unlawfully suspended, would resume as the court case against him had concluded. The
complaint was forwarded to Inspector Parsons to be dealt with by way of “Local Resolution”
(the statutory conditions were not met for the complaint to be handled that way). A complaint
may not lawfully be subjected to local resolution if the conduct complained about is
sufficiently serious to warrant criminal or disciplinary proceedings to be brought against the
person whose conduct is complained of (the complaint required fully investigating). This
decision is based on the wording of the complaint alone so the merit of the complaint or the
possible outcomes is irrelevant. The criteria for whether a complaint can be dealt with by
Local Resolution are set out in paragraph 6 (sub-paragraphs 6 to 8) of Schedule 3 of the
Police Reform Act 2002 Act, so despite the letter stating that the complaint was being dealt
with in accordance with this legislation it in fact was not.
7. The complaint concerned PA’s suspicion that the arresting officer had incited a witness to
commit perjury and had made a wrongful/unlawful arrest, leading to false imprisonment. The
force could not conceivably have been satisfied that if proven the conduct complained of
would not have justified the bringing of criminal and/or disciplinary proceedings against the
arresting officer. But despite the force obviously handling the matter unlawfully there is no
immediate avenue to redress such a statutory breach within the Police Reform Act. The
Independent Office for Police Conduct (IOPC) has no remit to intervene because the force is
entrusted to determine the Relevant Appeal Body (the RAB test) who will, depending on the
severity of the misconduct, be either the IOPC or the police force. In the present case the
5
An officer gave evidence in court which he knew to be false in Council Tax liability proceedings brought by North
East Lincolnshire Council. Indisputable evidence is held to support why the statement was untrue and why the
Claimant could not have believed it to have been true. It was clear from submissions in the proceedings that the
Council deliberately intended to deceive the court yet the “District Judge” nevertheless turned a blind eye.

5
police force was the Relevant Appeal Body, but only because the test was unlawfully carried
out and determined to be a complaint suitable to be subjected to Local Resolution. It is only
once the Local Resolution process has concluded that the opportunity arises for the
lawfulness to be challenged of the process by which the force determined the method of
investigation. Consequently, all the IOPC can do when the question of a breach of procedure
is raised with it is to pass the information to the force because the IOPC is not the Relevant
Appeal Body. It is almost certain therefore that the complaint was wrongly considered
suitable for Local Resolution deliberately in order to delay and obfuscate the procedure.
Mishandling the complaint bought Humberside police over 500 days which is how long it
took the force to complete the Local Resolution process. The force’s 29 December letter went
on to advise PA to contact the Professional Standards Department (PSD) if he was
considering making an appeal in relation to his conviction or sentence.
8. PA replied on 5 January 2016 explaining he had not made a decision on whether to make an
appeal but exploring the possibilities of doing so. He clarified that if he did appeal he
nevertheless expected the matter to be investigated whether or not he was successful. He
reiterated his concern about the two false witness statements made by members of the public
(he wanted clarification concerning those crimes he had reported). He made further enquiries
with the court which were responded to on 13 January. It was confirmed that he was able to
appeal against his conviction and sentence (Crown Court) even though the Trial took place in
his absence. He would need to include the reason why he was asking for permission to appeal
outside the 21 day limit in his notice of appeal. He was told that it was on the basis that he
made a conscious decision not to attend for his Trial in the Magistrates Court, for reasons he
had expressed in his e-mails that the Legal Team Manager considered it was not appropriate
to re-open the case under s.142 of the Magistrates Court Act 1980.
9. PA wrote to the Police on 1 February 2016 and confirmed that the Magistrates’ court had
refused to reopen the case6
and he was receiving no co-operation from the court regarding its
decision7
and therefore had “for the foreseeable future decided against appealing”. He asked
6
Section 142 of the Magistrates' court Act 1980 makes provision for reopening a case ‘if it appears to the court to be
in the interests of justice to do so’ including for the case to ‘be heard again by different justices’. Section 11 provides
that: ‘the court shall not proceed in the absence of the accused if it considers that there is an acceptable reason for
his failure to appear’.
7
A police letter stating that it did not investigate allegations of perjury unless requested to by the court was
forwarded to the court, along with evidence proving beyond all doubt that the Council’s evidence was perjured and
asked that it confirm this to the police. The court’s response was that it would not be taking any action regarding the
allegations of perjury.

6
for an update on the police force’s investigation into his complaint regarding the arresting
officer, and otherwise sought confirmation that the allegations of the two false witness
statements had been recorded as crimes. He had also written to the Magistrates’ court on 13
February with further representations to justify why his case should have been reopened. His
correspondence was copied to the PSD and had alleged collusion between the police, CPS
and Courts which was backed up with evidence. For example, (i) the case proceeded where
the evidence fell far below the minimum standards expected for a fair trial (in fact there was
no evidence), (ii) PA had been insufficiently informed about the proceedings and was
therefore completely in the dark regarding his rights, (iii) he had remained entirely voluntarily
to help police with their enquiries so the arrest was unnecessary and unlawful, (iv) it was
confirmed that a total of 7 CCTV cameras covered relevant areas but no request had been
made for the video footage to be retained on the relevant day and had consequently been
overwritten therefore video evidence had been concealed etc. etc.
10. The court’s Legal Team Manager replied on 15 February 2016 refusing again to reopen the
case. His justification was that PA deliberately chose not to attend the Trial on the 15
December 2015 and it was on that basis the case proceeded in his absence (he was unable to
challenge the evidence of the prosecution witnesses so the Judge found him guilty). He was
advised once more that if he wished to appeal the decision he should ask the Crown Court to
consider allowing him to appeal outside the time limit and if it allowed him to do so then he
could challenge the evidence of the prosecution witnesses.
11. The Manager was apparently unaware that a court may only convict if it is sure that the
defendant is guilty. Even if the judge had not bothered taking into account the various
documents PA had submitted to the court, there was enough conflicting material in the trial
bundle itself for the credibility of the evidence to have been in question and to have raised
doubt as to PA’s guilt. For example the witness statements were inconsistent with one another
and conflicted with what was said before they were produced. It was also clear from material
in the trial bundle that there were disclosure failings. These far exceeded what were first
apparent to PA and became evident once he began researching the laws (to challenge his
conviction) which were improperly applied at the time he was prosecuted. PA was not
prepared to stand before the same judge who he had not long since complained about to the
Judicial Conduct Investigations Office and reported the matter of complaint as a crime to the
police and declared unreservedly to the court shortly before the trial that he did not consider

7
the Judge, ‘a fit and proper person to hear the case’. Evidently the court could not have
considered these to be acceptable reasons for his failure to appear.
12. PA replied stressing the seriousness of his allegations and reiterated that he was alleging that
the police, CPS and Courts were complicit in allowing fabricated evidence to convict him for
charges of which he was innocent in order to defraud him of a sum of £620 and that the court
had no evidence whatsoever with which to find a guilty verdict.
13. The Police had not clarified any of the points which were raised by PA on 1 February 2016 so
he chased the PSD for an update on 9 February. Having still no reply he asked on 15
February whether Humberside police had any arrangements in place to restrict his contact, for
example, by telephone, email, letter etc., or a combination of these. He was responded to on
16 February and informed by the PSD caseworker that as far as he was aware there was no
such policy in place. It was clear from the reply that the PSD has no effective control over the
process once the file has been allocated to the Investigating Officer which must amount to a
dereliction of duty by the person responsible for the department. He expressed that he could
do no more than forward correspondence on to the Investigating Officer (he did not know
how the investigation was progressing), though made excuses for his failure to
respond/update, being that he was an operational Inspector implying his workload left him no
time to deal with the complaint. The PSD being conscious that the allocation to this officer
was inappropriate adds to the evidence that the completely unacceptable delay had been
deliberately engineered to cause injustice and therefore amounted to criminal misconduct (see
further admission that the choice of officer was inappropriate, para 24 below).
14. The PSD’s 16 February response did not address PA’s concerns about the two false witness
statements made by members of the public (it had still not been confirmed that these crimes
had been recorded). He formally submitted an on-line report on 29 February alleging perjury
with regards the false accounts produced by the witnesses. He informed Humberside Police’s
PSD of this on 4 March and attached a copy of the report. He also informed the caseworker
that he had submitted an on-line report alleging collusion between the police, CPS and Courts
which was relevant to his police complaint (a copy of the report dated 28 February 2016 was
also attached).
15. The Police responded on 11 March 2016 in respect of the on-line crime reports and reiterated
that the police force does not investigate allegations of perjury unless a request to do so

8
comes from the court. It was advised that PA raised these points with the courts and referred
to the letter sent to him dated 13th January 2016 which gave the same advice in respect of the
perjury allegations made about North East Lincolnshire Council. In response, PA suggested
that the police contact the court as he had already done so regarding the false statement made
by the Council and in doing so completely wasted his time. The PSD responded on 24 March
2016 in respect of the 4 March 2016 correspondence advising that the allegations made
within his complaint against the Police were not recorded as a crime as perjury is not a victim
based crime.
16. PA continued to raise concerns about irregularities in the Magistrates’ court proceedings as
they became evident, his most recent being an email he sent to the Legal Team Manager on
28 March 2016. He had discovered that the relevant Criminal Procedure Rules require that
when a defendant is absent the court must proceed as if he were present and had pleaded not
guilty. Also there was provision under the Magistrates’ Court’s Act 1980 for a defendant to
be tried on the papers alone. He contended that this would have been the procedure most in
the interest of justice as he was disadvantaged by having no legal representation and in the
dark as to his rights. He had submitted various documents of mitigating evidence which
would have been impermissible for the court to ignore had the case been tried on the papers
and plainly would have been the fairer option. Having taken this into account along with the
prosecution’s lack of evidence and the questionable, inconsistent witness statements, the
court could not conceivably have found a verdict of guilt.
17. He went on to say that the court had no power to find a guilty verdict merely on account of
the defendant’s failure to appear nor did the absence justify the judge allowing the solicitor,
who had been appointed to cross-examine the police and witnesses to withdraw from the case
(it must proceed as if the defendant were present and pleaded not guilty). He also discovered
that the bundle he was handed by the usher minutes before the 30 September 2015 court
hearing contained documents (material to the case), that apparently required serving in a
prescribed manner by the CPS which would not have entailed passing them on last minute
with no explanation as to their importance. In among the papers he was handed by the usher
was a letter (to defence where there is material to disclose) dated 22 September 2015 that
evidently required serving along with other material and should have alerted PA to any
implications of not being legally represented. The letter stated ‘I am required to disclose to
you any prosecution material which has not previously been disclosed, and which might
reasonably be considered capable of undermining the case for the prosecution or of assisting

9
the accused’s case’. The letter also set out the legal requirement for submitting a defence
statement among other instructions that he should have known about before his court hearing
of 22 September 2015. The failure to properly serve these documents clearly disadvantaged
PA not least because a schedule of unused material it referred to contained material
considered capable of undermining the case for the prosecution.
18. He stressed that the failure to explain and correctly serve the documents reinforced his
assertion that the authorities were complicit in disadvantaging him to the greatest extent
possible as a means to succeed in falsely criminalising and defrauding him. His rights were
further denied in respect of the sentencing hearing on 22 December subsequent to being
duped into opening the door to warrant officers who falsely claimed they were the police and
coerced him into attending court. He was locked up again and told while awaiting the hearing
that he would have access to the duty solicitor, however, this was untrue, he was not legally
advised but led directly to the courtroom in handcuffs to be sentenced for his wrongful
conviction.
19. The court responded on 12 April 2016 justifying how it was able to convict PA in
circumstances where it was inconceivable that the judge was sure of his guilt. According to
the Legal Team Manager it was possible because the judge was able to deny the existence of
material in the case file that undermined the prosecution because evidence of it was not
presented in person by PA in court. In other words, all that really matters is the perception
witnesses attending the hearing have of the judge’s certainty of a defendant’s guilt (even if
they are improperly informed); how sure the judge actually is himself does not come into it.
He reiterated that, PA made the conscious choice not to attend court for his trial (for whatever
reason) and the solicitor who attended to cross examine the prosecution witnesses on his
behalf had no option but to withdraw from the case as he was not there to tell him what
questions to ask. He was unable to explain why PA was not given access to the duty solicitor
at the sentencing hearing on 22 December but stated that there was no question of him being
defrauded or falsely criminalised as he had suggested. He reiterated that his option was to
appeal against his conviction and sentence to the Crown Court.
20. PA appealed the Magistrates’ decision to the Crown Court on 12 April 2016 with an
application for permission to appeal out of time. The appeal grounds to a great extent
consisted of the anomalies and failings that PA had already raised with the Magistrates
court’s Legal Team Manager. However, leave to appeal was refused on 15 April 2016 on the

10
basis that PA had deliberately absented himself from trial and he had put forward no adequate
reason as to the appeal being almost 3 months out of time. Evidently the Crown Court
deemed PA’s complete lack of confidence that he would receive a fair trial was not a good
enough reason for refusing to stand before the District Judge. His reasons for why he was
appealing out of time were attributable partly to his lack of knowledge of the criminal justice
system and being given no information regarding his legal rights. Other than that he had
carried out his own investigations; researched the law and had engaged with the Magistrates’
court which far exceeded the 21 days time limit within which PA would normally have had to
appeal (he had relied on satisfying the Magistrates’ court that it would be appropriate to
reopen the case).
21. PA had still not received an outcome to the 8 November 2015 police conduct complaint and
therefore prompted the PSD for an update regarding the progress of the matter on 3 May
2016. He alerted the force to some information he had discovered on the CPS’ website which
questioned the force’s motivation for not investigating the allegations of perjury. The force
had previously stated and maintained that, ‘Humberside Police do not investigate allegations
of perjury unless a request to do so comes from the court themselves’. However, the CPS
states that:
“Where a judge or magistrate believes that some evidence adduced at trial is perjured
s/he can recommend that there should be a police investigation. The absence of such
recommendation does not mean that there is no justification for an investigation.”
22. PA wrote to the Magistrates court on 9 May 2016 to express his view that he was able to
resume his attempts to get answers regarding the criminal way the court, police, CPS and
judges had dealt with this matter because his appeal options were exhausted. He criticise the
court’s rationale for refusing to reopen the case particularly for not taking into account
relevant factors. He reiterated his concerns about it being unreasonable to have expected him
to be tried by the same judge who he had complained about to JCIO (and the police), his
representations not being taken into account and the witnesses lying in their statements. He
objected to the court taking the view that he should have incurred the cost of appointing a
solicitor as a consequence of the corrupt police force (the police should have been
investigated for the alleged inciting of the witnesses to produce false statements). He went
on to say that the prosecution could not have proven the case beyond reasonable doubt, not if
the evidence had been considered, particularly the clearly inconsistent witness statements (he

11
would have been alerted to the conviction being unsafe). He suggested that the reason why
his written evidence was considered inadmissible was a ploy to conceal the facts from
attendee witnesses so as to justify his verdict of guilt. He viewed that the Crown court
refusing the appeal left the Magistrates’ court no alternative than to overturn the decision
under s142 of the Magistrates’ courts Act 1980 as it was aware from all the evidence that the
conviction was unsafe.
23. The Legal Team Manager responded 20 May 2016 reiterating that the court was not
prepared to reopen PA’s case (because he deliberately chose not to attend the trial). The
concerns regarding the criminal way the court, police, CPS and judges had dealt with the
matter were not addressed, they were merely dismissed as being outrageous.
24. PA asked the force on 13 October 2016 whether the Investigating Officer who was referred
the complaint had been instructed to discontinue the investigation as he had still not received
an update in respect of the 8 November 2015 police conduct complaint. He should have been
updated by 26 January 2016, assuming the clock started ticking when the Investigating
Officer was forwarded the complaint file. An update should be provided every 28 days from
that point, or, according to the IOPC, from when a complaint has been formally recorded
under the Police Reform Act 2002. The force’s 31 October response (below) reinforced the
view that the choice of officer to investigate was inappropriate:
“Insp Parsons has not been instructed to discontinue the investigation. As a duty
inspector, Insp Parsons is responsible for managing demand and resourcing; therefore
the delay in dealing with your complaint is due to high workloads and back log and will
endeavour to deal with your complaint when the opportunity arises.”
25. This and a telephone query made around the same time plus further calls made on 23 and 24
November 2016 were further opportunities for the force to assess the situation and conclude
it totally unacceptable to allow it to continue. Despite receiving an apology for the lack of
contact in January 2017 when the file was opened, there was still no update after another
officer spoken to on 27 February 2017 assured me that he would get a message to the
Investigating officer. If as the IOPC had stated a complainant should receive an update on
the progress every 28 days once a complaint had been formally recorded, there should
roughly have been around 17 updates, however, only one contact had been made (4 January
2017).

12
26. Several individual complaints were submitted to the police in quick succession each
concerning different aspects of the PSD’s failure over a period of 400 days to complete its
investigation into the 8 November 2015 conduct complaint. For example, the Investigating
Officer had failed to investigate the complaint and never once provided an update; the PSD
failed in its duty by not supervising the investigation; PA was never contacted on any of the
occasions he was informed by the person he made enquiries with that that they would get the
Investigating Officer to do so. The force consolidated the complaints and recorded the
concerns in respect of a submission date of 24 December 2016 and the concerns deemed
suitable to be dealt with by way of Local Resolution.
27. Shortly after (4 January 2017) the Investigating Officer sent an email of apology in respect
of the 8 November 2015 conduct complaint and admitted that he had just opened the file for
the first time (372 days after he had been allocated the case on 29 December 2015). In the
meantime, in respect of the of 24 December 2016 submission the force determined in an
outcome of 13 March 2017 that the PSD had done everything within its power to ensure the
investigation was being dealt with in a timely and professional manner. However, that did
not appear to have extended to anything more than passing on messages. The PSD must have
been aware that the work commitments of a duty inspector would cause difficulties for a
complaint to be investigated but referred the case regardless and took no initiative to
reconsider the choice of officer to deal with the matter.
28. The outcome of the conduct complaint of 8 November 2015 was eventually sent to PA on 3
April 2017. The Investigating Officer found that there was no wrong doing by the arresting
officer or any other parties involved in the matter (based on all the information available to
him). He considered that the Local Resolution process (the way he had dealt with the
complaint) was a suitable course of action in the circumstances. The outcome letter informed
PA that he was able to appeal the decision but to Humberside Police (not the IOPC) as his
complaint did not justify criminal or misconduct proceedings. Legislation governing the
complaint process does not allow any intervention of a decision like this to be put right until
the Local Resolution process has completed, therefore, from when the police wrongly
classified the complaint until he was given the opportunity to challenge the decision PA had
to wait 461 days. However, if you include the aggregate 51 days that it took for the PSD to
record the complaint and the period it had been unlawfully suspended this extended to 512
days. He had been caused gross injustice because a flaw in the complaint’s procedure

13
enables a PSD to classify a complaint, which the law requires to be fully investigated, as one
which can be dealt with by way of Local Resolution.
Complaint to the IOPC
29. PA had found out from research and advice from the IOPC what was required of the police
for it to be compliant with the law and also how the appeal system could be exploited by the
force to circumvent compliance with the same laws. For example he had learned that once a
complaint has been formally recorded the Investigating Officer was under a duty to send an
update on the progress of the complaint every 28 days and if a complainant is not sent a
formal recording decision within 15 working days of the force receiving his complaint, or
the force decide not to record it, he will have an automatic right of appeal to the IOPC to
decide if it should be formally recorded. He had prior to the 3 April 2017 outcome contacted
the IOPC about the delay (31 October 2016). He raised concerns about there being no
outcome to the investigation despite the fact 358 days had passed since he submitted the
complaint. He had telephoned the PSD earlier in October 2016 to enquire whether there was
an update and informed by the caseworker that Inspector Parsons was dealing with the
complaint who would be asked to contact PA (though never did). He informed the IOPC
about the response he had received that day to his request asking to know whether the
Investigating Officer had been instructed to discontinue the investigation (see above para
24). He considered the injustice of being wrongly convicted on false evidence etc.,
compounded by the subsequent failure of the PSD to take responsibility for the injustice
caused by the force (and a string of other failings) warranted charges bringing against senior
officers at Humberside police for Misconduct in public office.
30. The IOPC responded on 2 November advising PA that the Police Reform Act 2002 does not
state that an investigation should be concluded within a certain time frame (each complaint
is different and would be impractical for them to be dealt with within the same time frame).
It went on to say that the IOPC could not intervene in an ongoing investigation and could not
take any further action in relation to the matter. He was advised he would be provided an
appeal right at the end of the investigation and to raise his concerns then should he choose to
go down that route.
31. PA emailed a response on 20 November to put the IOPC in the picture regarding its
statement about being unable to intervene in an ongoing complaint because of an omission in
the Police Reform Act 2002 requiring an investigation to be concluded within a certain time

14
frame. He advised them that it was unlikely that the police had even begun the process as it
had stated that the Investigating Officer ‘will endeavour to deal with it when the opportunity
arises’ (see above para 24). He went on to say that the 358 days already gone by since the
complaint was submitted pointed to an abuse of the complaints procedure and it was the
abuse that was the issue not the IOPC’s non intervention in an ongoing complaint. It is of
note what the IOPC advises in its “Focus” series of guidance in respect of complaints being
investigated in a timely manner (regardless of there being no time limit). Though the
December 2016 Focus issue 10 had not been published at that point in time the relevant
content is below:
“There is no time limit for how long an investigation should take to complete – this will
obviously depend on the specifics of the case. However, all appropriate steps to
investigate complaints should be taken in a timely manner. This builds the confidence
of the complainant and the officers/staff under investigation, as well as ensuring the
integrity of the evidence. When investigating a potentially criminal allegation,
[Investigating Officers] should also be mindful of any statutory time limits for bringing
a prosecution.”
The IOPC does not consider the lack of provision for an investigation to be concluded within
a certain time frame to be a green light for proceedings to be delayed for so long that by the
time they have concluded any legal proceedings regarding the breach of Human Rights that a
complainant may have intended bringing upon the outcome, would be statute barred.
32. He asked for his concerns to be escalated to a person with the appropriate seniority and
responsibility to address the serious matters raised and who would not simply consider it an
attempt to circumvent the appeal process. He expressed his view that it would not have been
parliament’s intention when enacting the Police Reform Act 2002 that it should function as a
universal get out clause for the IOPC holding police force’s to account. He said in respect of
the advice that he should raise concerns (in his appeal) when the opportunity arose at the end
of the investigation that he had done that once before and his concerns were ignored. He also
reminded the IOPC about its own published statistics which revealed that Humberside Police
was one of the worst forces in the country with zero upheld appeals out of 106 complainants
who were unhappy with how their concerns were dealt with.
33. The IOPC’s response of 25 November was no help either. It reiterated that it was required to
act according to its role as set out in the Police Reform Act 2002 (it could not act where the
relevant authority to deal with a complaint/appeal, is the police force). It further advised that

15
PA should raise concerns directly with the PSD about the way the complaint had been
handled. In relation to his dissatisfaction with the complaints process, it suggested he raise
these concerns with his MP, as it is they who are able to influence legislative changes.
34. PA persisted with his complaint to the IOPC next writing on 4 December 2016. He insisted
that he was not asking for advice, nor did he expect the IOPC to intervene in the
complaints/appeal process. He was alleging serious misconduct of officers serving with
Humberside police therefore the legislation governing the complaints process was of no
relevance. He explained in respect of the suggestion to contact the PSD directly that he had
in fact done so in October and a further two times in November but had achieved nothing.
He suspected that the PSD had been instructed to palm off any queries relating to the matter.
He perceived that as soon as you engage with the police in a complaint the injustice suffered
increases tenfold because of the statutory framework of the complaint procedure (the police
exploit this to the detriment of the complainant). They would for example record a complaint
wrongly to deny an appeal right and/or prolong the process over several months or even
years with no intention of properly investigating it. He asked again for his complaint to be
escalated to someone who would consider his actual concerns rather than brush them off as
an attempt to circumvent the appeal process.
35. The IOPC’s response of 15 December exhibited the same inflexibility, i.e., it continued to
view PA’s enquiries as a way of circumventing the appeal process. It acknowledged that his
frustrations with the police complaints system were warranted, though in truth it was the
flagrant abuse of the complaints system which amounted to criminal misconduct that needed
addressing (not strictly the complaints system). The IOPC said it was not possible to have
the complaint escalated and reiterated that because the complaint was with the PSD of
Humberside Police it could not intervene in the matter (the process is set in legislation
therefore it could add nothing further). Ultimately the IOPC stated that any further email it
received in respect of the matter may be filed and not responded to.
36. PA decided he would no longer pursue his complaint with the IOPC, however, because of a
misunderstanding it had inadvertently resumed. A new unrelated complaint emailed on 4
January 2017 by PA to the PSD (copied to the IOPC) advised the force that if he did not
receive a formal recording decision within 15 working days he would have an automatic
right of appeal to the IOPC to decide if it should be formally recorded. The IOPC replied on
17 January 2017 under the misapprehension that PA had made an enquiry about how his

16
new conduct complaint would be handled. It reiterated what had already been provided in
various previous correspondence, i.e., (i) the force had 15 working days to make a formal
recording decision, (ii) there was no time limit for the completion of an investigation and
(iii) there was a right to appeal to the IOPC about the police’s recording decision. However,
it was stated additionally that ‘once a complaint has been formally recorded under the
Police Reform Act 2002 you should receive an update on the progress of your complaint
every 28 days from the Investigating Officer’.
37. PA replied on 25 February 2017, taking the opportunity to raise concerns about the failure of
the Investigating Officer to give an update on the progress of a complaint every 28 days but
in relation to the 8 November 2015 conduct complaint. He explained that the last contact he
had with the Investigating Officer was 9 January 2017 and he had been informed by him
only days earlier that the complaint file was opened for the first time on 4 January 2017 (the
complaint was submitted in November 2015). He asked whether it was likely that the force
was deliberately attempting to cause him as much injustice as possible and if so would there
be any action the IOPC could take against the force.
38. The IOPC responded on 8 March 2017 and confirmed that they had written to Humberside
Police’s PSD on 1 March 2017 to request an update on the conduct complaint of 8
November 2015 and was awaiting a response but had chased them again that day (they
would write again once they had an update). However, the IOPC did not write again, perhaps
because the PSD never replied but in any event the complaint outcome was sent
approximately a month later.
Returning to the Local Resolution outcome 3 April 2017
39. As stated (above para 28) the outcome of the conduct complaint was eventually sent 3 April
2017. PA replied on 5 April 2017 to the IOPC’s 8 March 2017 correspondence referring to
the outcome he had received the from Humberside police. He expressed his obvious
dissatisfaction with the fact that he had to wait over 500 days to obtain it, but to learn that
the investigation had been a sham just added insult to injury. He said he intended to appeal
the decision but was concerned about whether the complaint was suitable to have been dealt
with by way of Local Resolution. He had checked his records and found a letter dated 29
December 2015 from the force which stated that the complaint was considered suitable to be
dealt with that way. He queried whether there should have been a full investigation, bearing

17
in mind how serious the consequences had been for him and that the various matters if
proven would have had criminal consequences for those involved. He mentioned an IOPC
publication he had seen (practical guidance on handling complaints) which included a test
for establishing whether a complaint was suitable for Local Resolution or Investigation. He
located the document and quoted the relevant part of the test for assessing suitability for
local resolution, as quoted from the August 2014 issue (Focus), which is as follows:
“The suitability test
A complaint is suitable for local resolution if the appropriate authority is satisfied:
a. the conduct being complained about, even if proven, would not justify criminal or
disciplinary proceedings against the person being complained about...”
He wanted to know before beginning work on an appeal whether the force should have been
more diligent in determining the suitability of its approach to dealing with his complaint and
if there was a possibility that the force reviewed the matter. He attached the 8 November
2015 complaint and the letter of 29 December 2015 that stated that the complaint was
considered suitable to be dealt with by Local Resolution.
40. The IOPC replied on 5 April 2017 under the misapprehension that PA had submitted his
appeal to them rather than making an enquiry. He had clearly not submitted an appeal
because he stated in his enquiry ‘I would like knowing before I begin work on an appeal...’
He wrote back and explained that he had not submitted an appeal that day; rather he had
made an enquiry which he wanted addressing before he made his appeal. He asked if
someone would consider what he had actually enquired about in his email of 5 April 2017.
41. The IOPC replied on 6 April to say it was unable to comment on whether a complaint is
suitable for local resolution where it was not the relevant appeal body. It advised that if PA
disagreed with the Force’s decision to locally resolve the complaint, this would need to form
part of his appeal. It reiterated that he would need to contact the force directly as they had
decided that they were the Relevant Appeal Body to consider his appeal and there is no right
of appeal to the IOPC. PA wrote back thanking the IOPC for clarifying the matter and said
he would raise the issue in his appeal but would however appreciate being provided the
information he was seeking as a response to a general enquiry.

18
42. The IOPC wrote back responding to the queries PA raised in his email of 5 April 2017 and
advised that when the IOPC are not the relevant appeal body it cannot have any involvement
in the case. It referred to the suitability test PA had queried which states that ‘a complaint is
suitable for local resolution if the appropriate authority is satisfied…’. It emphasised that
the IOPC were not the appropriate authority therefore, if PA wanted the force to review the
matter, he would need to put this request forward to them. It added that the force do not
require consent to deal with a complaint via local resolution, therefore if he did not feel that
local resolution was appropriate, he should raise this as part of his appeal (it could not
comment any further). The IOPC was unable to (or would not) comment on the obvious fact
that the PSD had unlawfully opted for local resolution – a decision requiring the officer
making it to have genuinely believed that a police officer proven to have incited a witness to
commit perjury would not have justified criminal or disciplinary proceedings.
43. PA contacted the PSD on 7 April 2017 to query the 3 April 2017 local resolution outcome.
He raised the same concerns he had done with the IOPC on 5 April except he was not
seeking advice on the matters, rather he was asserting that the legal test to determine whether
the complaint was suitable to be dealt with by local resolution had been misapplied. He
stated that if the ‘suitability test’ had been properly applied, the most suitable course of
action in the circumstances would have been a full investigation. The PSD caseworker wrote
back simply stating ‘as per the documentation sent to you, you have the opportunity to
appeal. Please follow the information on the fact sheet should you wish to do so’.
44. PA responded (7 April) to say that he had taken advice from the IOPC regarding asking for a
review (the force had so obviously proceeded with the wrong process). He suggested that the
force would not have been ignorant of the fact that a full investigation was required and the
legislation governing misconduct complaints had been intentionally abused. He said that an
aggrieved person having an appeal right did not justify the PSD routinely recording
complaints wrongly or incorrectly opting for Local Resolution (it amounted to an abuse of
position for an officer to intentionally cause further injustice). Engaging in the appeal
process was not an insignificant undertaking which sometimes drag on for years. He
reminded the PSD that it similarly opted to deal with another of his concerns by way of
Local Resolution which should have been rigorously investigated because of the severity of
the misconduct. He considered having to engage further in the process on account of the
routine abuse of the Police Reform Act 2002 was a further injustice. There is no record of
the PSD caseworker replying.

19
45. The outcome was appealed on 22 April 2017 on the grounds that the statutory conditions
were not met for the complaint to be dealt with by Local Resolution (it required fully
investigating by law) and that the outcome did not reflect the evidence available. The
witness statements were discredited for being inconsistent and manifestly contrived. It was
suggested that the police may have a collection of standard “off the shelf” phrases that can be
incorporated into their statements for effect. A phrase claimed by the arresting officer in his
statement to have been said by PA was highlighted (“you can’t make me”) which PA
disputes to have said. This was coincidentally what was purportedly said to an officer in
relation to a separate incident alleged to have taken place on 27 December 2015 according to
the local press. The Code for Crown Prosecutors and the Director of Public Prosecution’s
Guidance on Charging were argued to have not been complied with (the prosecution was
proceeded with where the evidence fell way below the standards which would be expected
for a fair trial). There was no realistic prospect of conviction based on an objective
assessment of the evidence assuming the case would be heard impartially by a reasonable
judge properly directed and acting in accordance with the law.
46. The anomaly was raised about why no CCTV footage was asked to be retained when 7
cameras covered the relevant areas. PA was denied being informed of his rights to legal
representation, he was not aware of the position regarding his rights generally and it was not
explained to him the process other than being told dates on which he needed to attend the
police station or court. Representations he submitted to the Crown court accompanied the
appeal which set out in more detail the CPS obviously breeching its own code regarding
information it was required to disclose to him that was considered capable of undermining
the case for the prosecution or of assisting his case. He argued that the failure to explain and
correctly serve these documents reinforced his assertion that the authorities were complicit
in disadvantaging him to the greatest extent possible and everything else pointed to the CPS
and court colluding with the police in a malicious prosecution.
47. Humberside Police referred the appeal to the IOPC around 6 weeks later on 5 June 2017. It
was expected that the force would have deemed it appropriate to deal with the appeal itself,
however, the PSD stated that it had been forwarded to the IOPC as it was the correct appeals
body (based upon the wording of the complaint).
48. All the while PA was engaged in addressing the November 2015 conduct complaint he was
having to juggle other matters he had raised with the force. In order to keep this background

20
account manageable those issues will be referred to only generally where the need to
becomes unavoidable. Here it is necessary to refer to two emails sent to the IOPC on 4 and 8
June 2017 which were responded to on 13 June and had been filed under the IOPC’s
reference number for the November 2015 conduct complaint (though they referred to
separate matters). The 4 June 2017 email related to the complaints PA had submitted to the
PSD about the failure over a period of several hundred days to progress its investigation (see
para 26 above). The outcome had since been challenged predominantly on the basis that it
was unsuitable for Local Resolution and the Investigating Officer had not even opened the
complaint file until 370 days after he had been referred it (the appeal was not upheld). PA
had attached the papers in order to seek the opinion of the IOPC as to whether the force
failed to reach a correct decision based on the Statutory Guidance. He had quoted what he
had previously been advised by a Customer Contact Adviser to justify his potential request
for the IOPC to intervene:
“The [IOPC] can sometimes contact the force if it can be clearly shown that the police
force (appropriate authority) has failed to reach a correct decision based on the [IOPC]
Statutory Guidance. This could result in the force changing its decision. The [IOPC]
cannot unilaterally make the force change its decision.”
49. The 8 June email was sent on advice given by the force. PA had made criminal allegations
against the Investigating Officer and head of the PSD relating to the handling of his conduct
complaint of 8 November 2015 via the facility for reporting crime on the force’s website on
4 June 2017 (not a conduct complaint). The force telephoned PA on 8 June informing him
that the matter would be referred to the PSD who would likely refer the matter to the IOPC
but recommended he also send the IOPC details. PA did as advised and provided a copy of
the crime report.
50. The IOPC’s 13 June response was no help in respect of either of the queries. The papers
relating to the first query explained why it was inappropriate to conclude that the complaint
could not result in misconduct or criminal proceedings purely on the basis that there is no
time limit on how long the PSD take to deal with a complaint (re, Focus issue 10 - para 31
above). The appeal, which was included in the papers submitted to the IOPC for its opinion
contained the following representations:
“It is no defence to say that there is no provision under the Police Reform Act 2002 for
an investigation to be concluded within a certain time frame. It is understood that there

21
is no provision because it would be impractical to expect all matters to be dealt with
within the same time frame as all complaints are different. However, a delay caused by
the investigating officer not opening the file until 370 days after he had been allocated it
can not be attributed to the complexity of the complaint. A letter of 29 December 2015
stated that the file had been forwarded to Inspector Parsons to be dealt with but the first
contact he made regarding the complaint was an email sent 4 January 2017 in which it
was stated that the file had only been opened for the first time that day.”
51. However, the IOPC failed in its response to take into account two key factors. It had (i)
overlooked its own guidance, which had by that time been published which was that ‘all
appropriate steps to investigate complaints should be taken in a timely manner’ and the time
taken ‘will obviously depend on the specifics of the case’, and (ii) ignored the fact that the
Investigating Officer had sat on the case for 370 days without even looking at it. Its response
particularly regarding these points was as follows:
“I note from your email that you have queried who should be the relevant appeal body
for your police complaint. I note from the attached complaint form that your complaint
was regarding the length of time the [PSD] have taken to deal with a previous police
complaint...., stating that over 400 days have passed since you first submitted the
complaint, and failing to keep you update with its progress.
Please be aware that there is no time limit on how long the PSD take to deal with a
complaint, therefore your complaint could not result in misconduct or criminal
proceedings. Consequently, the [IOPC] would not be considered as the relevant appeal
body in this case.”
52. The rest of its response regarding this query was advice to PA that the IOPC could not
intervene (there was no further right of appeal) and of his options if he disagreed with the
appeal decision, as quoted below:
“Whilst I note you remain dissatisfied with the decision made in regards to your appeal
it is not within the remit of the [IOPC] to assist you in this matter. Please note the Police
Reform Act governing complaint procedures does not afford you a further right of
appeal against this decision through the PSD of Humberside Police or the [IOPC]. You
may however wish to challenge the appeal decision through judicial review. For further
information on this process please seek independent legal advice.”
It would constitute misconduct if a public officer entrusted to act impartially, fairly and
without discrimination or bias was found to have wilfully neglected to act as required.
Leaving someone who has clearly been caused severe injustice by a public authority no

22
alternative to a possible remedy than to pursue it in the high court when its decision was
indisputably wrong can not be considered free of association with misconduct.
53. The 8 June 2017 email informed the IOPC about the telephone call PA had received that day
from the force about an alleged crime he reported on 4 June 2017 and that the PSD would be
dealing with the matter and would likely refer it to the IOPC. The attached 4 June 2017
crime report (log 343 of 5th June) contained the following:
“I am reporting what I believe is a crime that has been committed against me by
Humberside police in allowing a complaint about the conduct of PC Thomas Blake to
have prolonged over a 510 day period (8 November 2015 until 3 April 2017).
My 8 November complaint alleged wrongful arrest and false imprisonment and
expressed my suspicion that the arresting officer incited a witness to commit perjury.
The witnesses had committed criminal offences by making false allegations which were
backed up in detailed statements to the police. Consequently they were liable to
imprisonment for perverting the course of justice and clearly should have been
investigated by the police and prosecuted by the CPS (neither happened).
Inspector Andrew Parsons who was referred the complaint (the resolving officer) had
not even opened the file until 370 days after it had been allocated to him. Therefore the
delay could not have been attributed to the complexity of the matter.
The [PSD] defended the resolving officer implying his workload left him no time to
deal with the complaint which suggests that the [PSD] were conscious that the
allocation to this officer was inappropriate and could have been deliberately engineered
to inflict the maximum injustice. Notwithstanding the incalculable amount of time I
have had to dedicate/waste on account of Humberside police’s negligence and
dishonesty, I have been denied my legal right to legal remedy because of the delay. For
example, it has benefited the force by ensuring that by the time investigations had
completed any legal proceedings regarding the breach of Human Rights that I may have
intended bringing upon the outcome, would be statute barred.
I therefore allege that Inspector Andrew Parsons and Chief Superintendent Judi Heaton
(head of the [PSD]) are complicit in abusing their positions for the purpose of achieving
a detriment to me for which they are liable to imprisonment under the Criminal Justice
and Courts Act 2015.
Humberside police Telephoned 8/6/2017. Said the matter would be referred to
Professional Standards but recommended the [IOPC] was sent details as well.”

23
54. The IOPC’s 13 June response did not give confidence that the issue had been carefully
considered. It noted from PA’s email of 8 June 2017 that he had submitted a new complaint
to the PSD on 4 June 2017 when in fact he had made criminal allegations that carry a prison
sentence under the Criminal Justice and Courts Act 2015 against the Investigating Officer
and head of the PSD. However, even if the IOPC had erroneously considered it to be a
complaint under the Police Reform Act 2002, it was a scandalous show of indifference for
an organisation whose statutory duty is to secure and maintain public confidence in the
police complaints system to have not found it necessary to intervene. Its response regarding
this query continues as follows:
“Normally this complaint would be forwarded onto the PSD of the appropriate police
force for their consideration. We note that your correspondence has already been sent to
the police and we will therefore be taking no additional action.”
55. PA responded on 30 June 2017 to clarify that the complaint which the IOPC referred to
dated 4 June 2017 was in fact a reported crime which was submitted on Humberside police’s
website and that the force rightly or wrongly treated it as a complaint. He said regarding the
complaint taking over 500 days to be addressed that he had already been informed in an
email dated 17 January 2017 (see para 36 above) that there was no time limit on how long
the PSD take because every complaint is different and varies in complexity. He stated that
the a delay caused by the investigating officer not opening the file until 370 days after he
had been allocated it could not be attributed to the complexity of the complaint; he had
expanded on this in the papers he had sent earlier for the IOPC’s opinion which suggested
that the delay was engineered.
56. The 11 July 2017 response demonstrated without question that the Customer Contact
Advisor was under orders to deflect any issues wherever possible that might otherwise have
increased the workload for the IOPC. She had achieved this by focussing on content she was
able to exploit whilst overlooking the salient points as the response below testifies:
“I note from your email that you wish to clarify with us, that your police complaint was
actually a report of crime, which has been wrongly treated as a police complaint.
Please note that the [IOPC] does not get involved with criminal matters i.e. we have no
power to intervene in or change the outcome of a criminal investigation, we solely deal
with cases of police misconduct. I would therefore advise you discuss any criminal
matters you have or wish to report with the police directly.

24
I have filed your correspondence under the above reference number and will be taking
no further action.”
PA replied simply to thank the Customer Contact Advisor for her response but expressed
that he had evidently failed to make himself clear in his 30 June correspondence.
57. PA sent additional information to the IOPC on 13 July 2017 to supplement his 22 April 2017
appeal because he had in the meantime received a relevant Decision Notice (28 June 2017)
from the Information Commissioner relating to a Freedom of Information Request he made
to Humberside Police (he provided the decision). He had made the request in the hope of
obtaining evidence to support his assertions that the police officer’s Witness Statement
relating to his wrongful conviction contained inaccuracies. He had provided in his 22 April
2017 appeal a possible answer for why the arresting officer stated in his written account that
PA had replied to him ‘you can’t make me’ when he disputes having said this (re, incident
reported in local press - above para 45). The news article reported that a Humberside police
officer had been assaulted and the exact phrase was supposedly said by the accused as the
one in question, i.e., relating to PA’s wrongful conviction.
58. It occurred to him that it might have been a standard phrase used by police in their witness
statements and wanted to know if it formed part of a collection of ‘off the shelf’ phrases they
slipped into their statements for effect. He therefore requested the number of times the
phrase “YOU CAN’T MAKE ME” appeared in police officers witness statements and for
disclosure of the officer who included the expression where it was found in a statement. The
force refused to answer the request on the grounds that it was vexatious and the
Commissioner who had been subsequently referred a complaint agreed with the police that
there was no serious purpose and upheld its decision that it applied the vexatious exemption
correctly. Ironically the outcome was useful, despite the Commissioner upholding the
vexatious exemption because it inadvertently revealed that the police officer who PA had
alleged to have inaccurately set out his Witness Statement relating to his wrongful
conviction was the same constable involved in the aforementioned news article. His point
was that the use of standard (not necessarily true) phrases were possibly being incorporated
into Witness Statements to the detriment of the defendant. The IOPC confirmed in an email
of 19 July 2017 that they had received the additional representations and had been added to
the case and would be reviewed once it is allocated to a casework manager.

25
59. On completing the review (29 August 2017), the IOPC deemed the statutory conditions were
not met for the matter to be suitable for Local Resolution and directed the force to fully
investigate the complaint, taking into consideration further information such as evidence in
support of alleged collusion between the police, CPS and Courts concerning the lack of
securing CCTV and rights to legal representation etc. A complaint may not lawfully be
subjected to Local Resolution if the conduct complained about is sufficiently serious to
warrant criminal or disciplinary proceedings to be brought against the person whose conduct
is complained of. The casework manager said she would provide a copy of the additional
documentation concerning the Commissioner’s Decision Notice to Humberside Police for
consideration and recommend the Investigating Officer review both sets of appeal
correspondence before finalising with PA details of the complaint.
60. The casework manager commented additionally that there was insufficient evidence to
suggest that a proper outcome had been reached (even if the complaint had met the threshold
test to be locally resolved) and referred to Regulation 6 of the Police (Complaints and
Misconduct) Regulations 2012. Regulation 6 requires that the person appointed to deal with
a complaint must provide both the complainant and person complained against an
opportunity to comment on the complaint. She noted, however, that there appeared to be no
evidence of any dialogue between PA and Humberside Police, nor an action plan or details
of what steps would be taken by the Investigating Officer to resolve the complaint. Although
she had decided the complaint should be investigated, she would still provide feedback to
the force about the lack of communication with PA and the importance of giving all
complainants an opportunity to feed into the Local Resolution process, so learning can be
taken from the case. Finally, the casework manager advised that the further complaints PA
apparently had concerning both the CPS and the Court would need to be made directly to
them as the IOPC had no jurisdiction.
61. The PSD wrote on 22 September 2017 regarding the 8 November 2015 complaint and appeal
subsequently upheld by the IOPC on 29 August 2017 and informed PA that his complaint
had been considered suitable for a proportionate investigation and would be dealt with at a
local managerial level. His complaint had been forwarded to the new Investigating Officer
(IO) who would be contacted in due course.
62. PA responded on 29 September 2017 (IOPC copied in) to query the decision made by the
PSD that the complaint had been considered suitable for a proportionate investigation.

26
Humberside police’s investigations fall under either one of two categories (full or
proportionate). Both have prescribed procedures – the proportionate being of less scope than
the full investigation thus the proportionate is more limited in scale. PA argued that the
complaint ought to have been considered suitable for a full investigation on account of the
seriousness of the allegations and the degree to which he had been affected by the injustice
arising from the matter. He emphasised that the IOPC casework manager had recommended
that the appointed IO consider the additional submissions, namely the 22 April 2017 appeal
and the further representations dated 13 July 2017 which he understood to have been
forwarded to the PSD. He argued further that the matter clearly warranted the most
comprehensive investigation given that the additional representations dealt with such matters
as collusion (police, CPS and courts), failure to secure CCTV footage, witnesses liable to
imprisonment for making false allegations in detailed statements to the police and denial of
rights to legal representation etc. It was also evident on exploring which issues would be
relevant for investigation that there had been clear breaches of the Criminal Procedure and
Investigations Act 1996. This, he said, reinforced the necessity that the matter received the
fullest commitment by the force.
63. There is no record of a response from the PSD, however, the IOPC casework manager who
was copied in replied on 2 October 2017. Though she noted PA’s concerns she said that the
IOPC would not be commenting or giving direction regarding the scope of the complaint
investigation, as they did not wish to prejudice the investigation and right of appeal that
would be afforded PA at its conclusion. All they could do at that stage was place his email
on the file. It had already taken 694 days from when the complaint was made until this point.
The most significant factor contributing to the delay so far had been the lack of provision in
the Police Reform Act 2002 to remedy an erroneous decision to locally resolve a complaint,
i.e., where the requirements are not met for a complaint to be lawfully dealt with by Local
Resolution. The same anomaly that led to the injustice of being tied up in a dispute with the
force for almost 700 days was starting over because the opportunity to challenge the
lawfulness of the investigation method does not arise until the Local Resolution process has
concluded (the complainant is then able to appeal).
64. The IO who had been forwarded the complaint on 22 September 2017 made first contact
with PA on 12 February 2018 and asked if he wanted to meet to discuss the issue (he replied
stating that he preferred everything in writing). In reference to the IOPC letter of 29 August

27
2017 (finalising details)8
he queried whether it was this stage the IO was presently at. He
mentioned that he had been working on a paper that would contain essential factors for the
investigation to take into account that focussed heavily on disclosure failures of the police.
He explained that although the document was intended for Humberside police to assist in the
investigation it also focused on a number of key areas considered relevant for the CPS and
Magistrates’ court to examine in respect of his complaint and allegations which also
focussed on disclosure failures. He said it was on the recommendation of the IOPC that he
did this and quoted the relevant part of their 29 August 2017 letter which was as follows:
“On a separate note it appears you may also have complaints concerning both the
Crown Prosecution Service (CPS) and the Court. As the [IOPC] has no jurisdiction over
these two formal bodies, please make your complaints directly to them”
He told the IO that he had almost incorporated everything he intended to include and hoped
to have the document completed within the week. The IO replied to ask PA if he wanted her
to wait until he had completed the representations. He agreed it was the best way to proceed
and would send the supporting document to the IO when complete which he did on 19
February 2018.
65. PA forwarded the 19 February representations to the CPS accompanied by the following
covering email (he did similar in respect of the court) on 20 February 2018.
Dear Sir/Madam
Please forward this email and attachment to the person who deals with correspondence
from those wrongly convicted in respect of material which comes to light after the
conclusion of proceedings (see paragraph 59 Attorney General's Guidelines).
“Post-conviction
The interests of justice will also mean that where material comes to light after the
conclusion of the proceedings, which might cast doubt upon the safety of the
conviction, there is a duty to consider disclosure. Any such material should be
brought immediately to the attention of line management.”
8
‘In the circumstances, and as part of my direction to investigate your complaint, I will recommend the person
appointed to investigate your complaint reviews both sets of your appeal correspondence before finalising with you
details of your complaint and what the investigation will consider’.

28
A police conduct complaint in relation to this case was submitted on 8 November 2015
and initially dealt inappropriately by Humberside police by way of Local Resolution.
The outcome provided on 3 April 2017 was appealed and referred to the Independent
Office for Police Conduct (IOPC). On completing the review, the IOPC deemed the
statutory conditions were not met for the matter to be suitable for Local Resolution and
directed the force to fully investigate the complaint, taking into consideration further
information such as evidence in support of alleged collusion between the police, CPS
and Courts.
The IOPC letter upholding the appeal against Humberside police (29 August 2017)
stated;
“On a separate note it appears you may also have complaints concerning both the
Crown Prosecution Service (CPS) and the Court. As the [IOPC] has no
jurisdiction over these two formal bodies, please make your complaints directly to
them”
In light of the systemic failures reported in the national press recently regarding
disclosure issues it is appropriate (in addition to the IOPC recommendations) that the
CPS looks again at this case.
Although a defence statement I submitted unwittingly raised disclosure failures, these
now have been more clearly identified and set out in the attached representations. Note:
Because of disclosure failings, the defence statement was not sent to the CPS (only the
court).
It is noted that the Chairman of the Criminal Cases Review Commission reportedly
stated that “non-disclosure of material that could prove a suspect's innocence is the
'biggest single problem’ affecting the right to a fair trial” so it is now very much in the
public interest that this case is reviewed.
66. The IO acknowledged receipt of the document and said that she would go through it and be
in touch. She next contacted PA on 17 April 2018 to say that she was still reviewing the
document and would update him as soon as possible. On 27 May the IO produced a list of 22
key areas she believed PA considered relevant to investigate and sought confirmation from
him. PA wrote back to confirm that the issues raised in the report seemed to have been
covered comprehensively, though expressed his concern that a number of the issues might be
filtered out for investigation because they might not be considered in jurisdiction. He asked
to be informed sooner rather than later if that was the case and added that he had done as the
IOPC recommended regarding making complaint to the CPS and Court separately (he had

29
forwarded the 19 February document to both those authorities). He made further comments
to assist and give additional clarity in respect of the issues that the IO had identified and
itemised a number of supplementary areas to incorporate under the generally described
“abuse of process” (IO’s item 9) which were as follows:
Force proceeding to charge in circumstances where the law required no further
action to be taken
Solicitor no longer acting for [PA] (discovered minutes before the court hearing)
Failure to keep case under review to assess whether prosecution material might
reasonably be considered capable of undermining the prosecution’s case and
whether or not it should have gone to trial
Inconsistent witness statements of the Johnsons (5 day delay in obtaining Mrs
Johnsons)
Failure to investigate perjury allegations (the Johnsons)
67. The IO next contacted PA on 27 July 2018 to inform him that she had been consulting with
the PSD as to how to go about dealing with the complaint due to the complexity of PA’s
report and some items did not relate to the Police. The PSD had advised her that she was
dealing with the 2 recorded allegations as below:
The complainant alleges an officer unlawfully arrested the complainant for the
offence of Indecent Exposure.
The complainant alleges an officer has incited a witness to commit perjury.
She was also advised by the PSD that if there was anything else PA wished to complain
about, he would have to go through the normal route of reporting it to the PSD. She had
almost completed her findings as a consequence and would update PA by the end of the
week that followed.
68. It was clear that the PSD were pulling a fast one and wanted to restrict the process to
investigating the allegations as they had been briefly recorded therefore disregarding even
some relevant initial concerns and certainly any that had been discovered throughout the
process including what the IOPC had recommended as part of their direction to have
Humberside Police carry out the investigation. PA wrote back as follows:
Thank you for your email.

30
I can assure you that the [PSD] are leading you up the garden path by instructing you
that the investigation should be restricted to the matters briefly described in the recorded
complaint report of 24 November 2015 which were based on the preliminary
representations made in the initial complaint of 8 November 2015. The prescribed
complaint form states on it that “at this stage we only require a summary of your
complaint” and by that it is clear that the PSD would not expect the issues to be
comprehensively set out on the 8 November complaint form. The force is obliged to
take into account all of the representations including those which have been provided
additionally during the process.
Please bear in mind that the PSD is infested with corruption and have most likely
advised you this way because a significant amount of my complaint focuses on the
PSD’s own fault and negligence which contributed to my wrongful conviction. The
suggestion by the PSD to turn a blind eye to all other matters identified during the
protracted process so far is a good indication of the corrupt way the department operates
which is to primarily cover-up wrongdoing and prevent those who have been victim to
it obtain appropriate redress.
I am assuming (probably wrongly) that all the papers relevant to this matter are with
you. I would appreciate if you would itemise everything you hold so I can be assured
that the PSD has not been selective with what it has made available for your
consideration. For the avoidance of doubt, the overall objective of the investigation is to
identify and deal appropriately with all elements of fault and failure for which the force
was responsible which contributed to my wrongful conviction (see 19 February report,
para 2).
“The investigation must essentially identify all failings that led to the miscarriage
of justice. For the avoidance of doubt, the wrongful arrest, false imprisonment and
alleged incitement to commit perjury set out in the 8 November complaint form
only part of the overall injustice which is now evident needs to be investigated.
The prescribed complaint form in any event made it clear it would not be expected
that the issues were comprehensively set out initially....”
Regarding the advice that 'if there is anything else you wish to complain about, then you
would have to go through the normal route of reporting it to the Professional Standard
Branch'; this is further evidence of the aforementioned corruption. The Professional
Standards Branch has ensured that the delay in dealing with this matter (approaching 3
years) has prejudiced any legal rights I would ordinarily have had to pursue redress. For
example, the department has advised this knowing that if I were to waste more of my
time going through the normal route of reporting it, the complaint would be rejected
(disapplied) as invalid for being a complaint made out of time.
However, I can assure you that the PSD has also misled you in this respect because the
Independent Police Complaints Commission's letter of 29 August 2018 upholding my

31
appeal and directing the force to carry out an investigation into the complaint states the
following:
“I note from your original appeal documentation, dated 22 April 2017 and further
representations, dated 13 July 2017, that you appear to provide both further
information in support of your complaint and potentially new complaints such as
collusion between the police and the CPS/Courts concerning the lack of securing
CCTV and rights to legal representation etc.
In the circumstances, and as part of my direction to investigate your complaint, I
will recommend the person appointed to investigate your complaint [this has to be
a person who hasn't participated in attempting Local Resolution] reviews both
sets of your appeal correspondence before finalising with you details of your
complaint and what the investigation will consider.
Whilst Humberside Police already have on file the appeal you submitted on 22
April 2017, I will provide a copy of the additional documentation, dated 13th July
2017, to Humberside Police for consideration; a copy of which is attached to this
decision letter for your information.”
Clearly all the concerns raised in the 22 April 2017 appeal are expected by the
Independent Police Complaints Commission to be considered, so that includes
everything from the initial allegations in the recorded complaint report of 24 November
2015 to the wholesale corruption of the PSD detailed in the 19 February report implied
initially in the 22 April appeal.
I obviously do not know the true extent to which the PSD has engaged with you on this
matter but from taking your correspondence at face value it would be reasonable to
assume that you have been taken advantage of (put-on) by the PSD if it expects the
comprehensive set of issues to be dealt with entirely by yourself. Perhaps if the PSD
was not the dysfunctional outfit that it is, it would have split the investigation in
accordance with Regulation 25 of the Police (Complaints and Misconduct) Regulations
2012, i.e., due to the complexity of the complaint.
69. The IO said in a 28 July response to PA that she had taken into consideration what he had
explained and would detail all of the investigation documents she had in the proportionate
investigation letter that she was currently typing to him. She hoped this would be completed
within the week and would update him in due course. On 8 August 2018 the IO wrote to say
she had submitted her findings for review and he should receive her letter shortly.

32
PA had not received outcome purportedly sent 12 September 2018
70. PA wrote to the IO on 8 October 2018 stressing that the matter had dragged on for almost 3
years without resolution and therefore would appreciate being informed what was
happening. He had assumed that the force was required to carry out further investigations
before the outcome could be finalised due to the review that was referred to in the IO’s 8
August 2018 email. The IO wrote back to say she had forwarded his enquiry onto the PSD
who had her letter to review though she was under the impression PA should have received
it by that time.
71. PA replied on 8 October to say that he understood it was the IOPC who were supervising the
complaint and it would be that organisation reviewing the matter. His opinion was that the
PSD should not have been allowed to have any influence on the outcome/findings because
there were officers within that department desperately requiring investigating for criminal
misconduct. He also included in his allegations the previous IO who had mishandled the
complaint initially and the assistant force solicitor who routinely dealt with appealed
complaints unlawfully in-house. The IO stated in her reply on 9 October that she had been
informed that the letter had been sent on 12 September 2018 (by her) and asked PA if he
could confirm he had received it.
72. PA wrote back to the IO and stated that she knew he had not received the letter (he had
written about the delay the previous day). He added that a copy would have also been sent to
the IOPC (if it had been sent) so could it be confirmed that the IOPC received the letter. He
also figured that the embedded file properties of the document in its electronic form would
answer some questions so asked to be sent the letter to him as an email attachment (the force
would be required to save it to its system). He asked for the IO to arrange for this to be done
so he received it by 5:00pm that day. The IO said in her reply that she was not aware that PA
had not received the letter; the procedure, she said, was that the IOPC review the appeal and
then send it back to the force for them to carry out further investigations if required. She
explained that she had carried out the further investigations and responded to all of them in a
letter (presumably the investigation outcome), which is sent back through to their PSD for
review, prior to them sending it out to PA. She had been informed that this process was
completed and PA was sent the letter on 12 September but asked the PSD to re-send the
letter to him.

33
73. PA wrote to the IO and PSD on 9 October asking for the file which was saved to the force’s
system to be sent to him as an email attachment while he awaited a copy through the post.
However, he stressed that he wanted a copy of the original file (presumably created 12
September) not one produced subsequent to his request. The PSD caseworker sent copies of
the paperwork purportedly sent to PA on 12 September 2018 as email attachments on 10
October 2018.
74. PA viewed the properties of the two electronic documents he had been sent which revealed
that they had been created shortly before they were emailed to him on 10 October 2018. He
also noticed that the address on the letter, all but his name, was incorrect. He took a screen
shot of the information showing the time and date the files were created and the incorrect
address and attached it to the email he sent to the PSD on 10 October (see below):
I am writing in response to the email you sent 10 October 2018 (attached) in which you
wrote the following:
“Please find attached copies of the paperwork sent to you on 12 September 2018”
Thank you for these files. However, as the pdf attachment verifies, the files relating to
the paperwork purported to have been sent to me on 12 September 2018 were created
today, 10 October 2018.
I specifically wanted the files which were saved to the force’s system at the time when
the letter was sent (12 September).
I would also like to point out that you know my correct address and have sent letters
previously which have successfully reached me and would therefore like to know why
on this occasion my address on the attached 12 September letter is completely wrong.
I note the letter states the following with regard to the time within which I have to
appeal to the IOPC and that the deadline is 10 October 2018 (the day I received the
outcome):
“You have 29 days from the date of this letter, within which to make your appeal
to the IOPC. You are advised to post your appeal in good time to ensure it reaches
the IOPC before the end of the 29th day. The 29th day is 10 October 2018.
Appeals received after 29 days may not be allowed unless there are exceptional
circumstances. You might want to consider using guaranteed next-day delivery
post service to ensure that your appeal is received within time.”
Please send me the files which were saved to the force’s system at the time when the
paperwork was sent.

34
75. The PSD caseworker stated in her reply that the paperwork was the same as what was sent to
PA on 12 September 2018. She advised that it had been changed to pdf format before
sending it as an email attachment for security purposes. She added that she would make a
note on the file that it was sent to the incorrect address and that the time within which PA
had to appeal would be extended to 8 November 2018 (29 days from 10 October).
76. PA took the view that if the paperwork had in fact been sent to someone else’s address
(though he had reservations about this actually happening) there was a far more serious issue
to be remedied than merely the time limit for appealing the decision. He therefore expressed
this in his subsequent email to the PSD (see below):
“The letter has obviously not been returned to the force so it is reasonable to assume
that whoever received the paperwork may have accessed the contents.
You will be aware that sending somebody’s personal information (paperwork of a
sensitive nature in my case) to somebody else’s address amounts to the unauthorised
disclosure of personal data (a personal data breach). I trust that the force will have
already or will be about to notify the Information Commissioner (ICO) in accordance
with the General Data Protection Regulation (GDPR).
The breach is made worse because of the nature of the contents and even more serious
because within the report are a number of instances where the police – though
completely irrationally – have agreed with the version of witnesses against whom I have
alleged (and proven) to have committed perjury in their written accounts.
Please let me know what action the force intends to take in this matter.”
The PSD sent a letter dated 12 October 2018 thanking PA for his complaint which it had
received on 10 October and said that the issues raised were being considered by a manager
and he would be contacted again in the near future.
77. PA’s email above (10 October) was not intended as a formal complaint but was handled as
one by the force in accordance with the complaint’s procedure under the police reform Act.
His email was predominantly to alert the force of its obligations to refer the personal data
breach to the Information Commissioner and to obtain some preliminary information in
anticipation of submitting a complaint (to the force) in case it was a prerequisite to raising
the issue with the Commissioner. The complaint was formally recorded on 29 October 2018
and the description on the ‘Complainant Record’ read as follows:

35
“The complainant alleges that a Proportionate Investigation letter was sent to an address
which is not his, and that this amounts to an unauthorised disclosure of personal data.
He states that this is exacerbated by the content of the letter.”
The letter of the same date informed PA that the file had been passed to a caseworker who
would do some initial evidence gathering before forwarding it to an IO. He was informed by
the PSD on 29 November 2018 that the complaint had been forwarded to Superintendent
5658 HALL who would contact him in due course.
78. On 7 December 2018 PA wrote to the PSD regarding the personal data breach to find out
what the situation was. He wanted to know, for example, whether the letter had been
retrieved from the incorrect recipient and if the force had referred the matter to the
Information Commissioner. He said he was aware that some issues were being dealt with as
a complaint under the Police Reform Act 2002. In the absence of a response he contacted the
PSD again on 27 December and asked if the letter had been retrieved, whether it had been
opened or not and who occupied the property to which the letter was incorrectly sent. Again,
the PSD did not reply.
79. PA was next contacted in relation to the complaint on 10 January 2019, though not by
Superintendent HALL who had been forwarded it to investigate, but Superintendent Joanne
5505 Roe9
. She announced that she had taken up post as the IO’s Line Manager on 7 January
and informed PA that she was in the process of conducting an investigation into the
complaint he had recently made. She had all the necessary information and would be more
than happy to discuss with him the investigation and would keep him informed of progress
and findings – he should not hesitate contacting her for further information. It had not been
explained why Superintendent HALL was no longer Investigating the complaint, not by
Superintendent Roe or the PSD.
80. PA wrote back highlighting that the latest correspondence communicating to him the
progress of a complaint he had unwittingly made in October 2018 was a letter of 29
November 2018 stating that the matter had been forwarded to Superintendent HALL who
would contact him in due course. He clarified that he had not then intended to make a
complaint, rather he was making enquiries about the Investigation letter that had apparently
been sent to an address which was not his. He quoted the contents of the final email he sent
9
There is some doubt as to the rank held at the time by Police Officer Roe as it is understood that she was promoted
to Superintendent on 21 June 2019

36
to the PSD on 10 October 2018 (see above para 76) which the force had interpreted to be his
complaint. The questions he had raised were never answered despite him prompting the
force again on 11 October, 7 and 17 December 2018. He said that the allegations recorded in
the ‘Complainant Report’ of 29 October did not detail all of the concerns he had raised, only
that he had alleged that the letter had been sent to an address which was not his. He also
questioned why Scunthorpe Police Station was the location attributed to where the matter
had arisen when the PSD, which is located in Hull, was responsible for sending out the letter
(see above para 72). He stressed that the anomalies he had raised needed to be addressed
before the matter could go any further.
81. In the absence of a reply PA contacted Superintendent Roe (the most recent IO) again on 21
February 2019 alerting her to his correspondence he sent on 10 January 2019 and that he had
not had a response and wanted to know what progress had been made. She responded on 22
February apologising for not replying sooner and said she was aware that he had raised
several matters with the PSD some of which were being dealt with by them10
though she was
dealing with the Data Breach matter. She referred to PA’s previous email (10 January) i.e.,
his statement that he had not intended to make a complaint, but enquiring about the missing
Investigation letter, and wanted the position clarifying (she would liaise with her PSD
colleagues with regards to the other matters and send further correspondence).
82. PA wrote back to find out what progress had been made. He wanted to know why the IO had
said that she was dealing with the complaint, but at the same time implying that she had
ceased dealing with it simply because he had stated that his communication of 10 October
2018 was not intended as a complaint but to find out specific details about the infringement
of his data protection rights. He emphasised that his questions had never been answered, so
he still did not know if the letter had been retrieved from the incorrect recipient or whether it
had been opened or not, or, whether the force had notified the Information Commissioner in
accordance with the GDPR. He said this was just preliminary information he considered
would be required to outline a complaint if it was necessary, i.e., if it was a requirement for
the matter to be dealt with this way before he could escalate it to the Information
Commissioner. He expressed his opinion that the force jumped the gun, but the PSD
obviously considered it was a matter that required processing through the complaints system.
10
Matters raised in correspondence with the force namely on 9 and 10 October, 7 and 17 December and 10 January
2019 (along with the Data Breach representations) referred to allegations of fraud, perjury, criminal misconduct etc.
which were all perversely dismissed as being unfounded when the evidence was conclusive. Details have been
omitted in the background account so as to limit the complexity of the matter.

37
He referred to correspondence he had been sent by the Information Commissioner on 20
December 2018 in respect of escalating the matter, quoting from it the following:
“If you have contacted Humberside Police about the problem but have been unable to
resolve the matter, you can raise a complaint with us via our how your information is
being handled reporting tool”.
He said he had given the force plenty of opportunity to at least deal with his preliminary
enquiries so if he was not given assurance that it was being dealt with by 1 March 2019 he
would consider the force had been unable to resolve the matter and raise a complaint with
the Commissioner as she had advised.
83. In the absence of a reply PA submitted a complaint to the Information Commissioner on 2
March 2019. He set out briefly on the prescribed form that his data protection rights had
been seriously infringed owing to the force divulging details of a criminal record he had,
resulting from a wrongful conviction. He wanted the Commissioner to establish whether his
personal data had been sent to the wrong address maliciously for example to put him at risk
of being pursued by vigilantes who would not stop to question whether the conviction had
resulted from false allegations and that no such offence had been committed.
84. The IO replied on 3 March 2019 explaining that she was in the process of finalising a letter
to PA to address the matters he had raised and asked if he would prefer to be emailed the
letter or have it sent recorded delivery. She was not, as PA assumed, referring to a letter
informing him of the progress she was making but to the final Investigation outcome of his
complaint. The IO had ignored PA’s requests for information about the complaint she was
dealing with under the Police Reform Act and ploughed on regardless to arrive at her
findings. In doing so she breached s.20 of the Police Reform Act that required her to provide
PA with all the information that would have kept him properly informed, for example of the
investigation’s progress and any provisional findings while she was carrying out the
investigation. She had also failed to comply with the statutory guidance to the police service
on the handling of complaints which requires Investigators to manage the provision of
information to complainants, and be in a position to deal with requests for information and
questions in the course of an investigation.
85. PA wrote back to explain that he had done as he said he would if he had not been given
assurance by 1 March 2019 that his complaint was being dealt with, i.e., he would consider

Letter before action 26 sept 2019 r

Letter before action 26 sept 2019 r

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