Ryan
v
Cambridge JCP and Cambridge City Council
Statement of Facts and Grounds
Statement of Facts
Introductory
The claims of unlawful eviction against CCC
Who helped CB do this in the DWP?
Ms S
"To progress your Third Party Verification request DWP requires you to complete , sign and return the forms via the return envelope supplied. Whilst email maybe your preferred option this will not be accepted as confirmation of your consent or verify your identity.... alternative options offered of either a face to face appointment, a phone appointment with Biographical questions or a home visit we would be happy to arrange this."
"On Wed, 25 Jun 2025 at 12:28, CCC <CCC@cambridge.gov.uk> wrote:Dear RyanI can confirm that I have just received an email from UC asking me to verify your Identification by confirming your tenancy details below. I have just responded and agreed with their statement [:]
"Hi Sarah,All I need to confirm is the landlord has been reported as Cambridge City Council (City Homes) – do you represent them? If so are you able to confirm the statements below for me please? If you can get back to me urgently I would really appreciate it."
Ms H
I have the following disabilities:
History between DWP and Ryan
History between CCC and Ryan
- CCC540399813
- CAM399855 Shower 2019 to March 2020 - cannot change shower without OT report
- CAM626654 OT Bath 2021, Installed the smallest bath, without the recommended shower.
- CAM113571 Bath 2023, (We have no other size baths, be patient)
- Asked Race discrimination Charity 2024. - Shower and larger bath installed winter 2024.
- 24 Oct 2025, the Bathroom is still incomplete; disrepair: bath lets in insects from outside. Bath tiles are covered in glue and pealing.
Facts
CCC's 4 Sept 2025 request for reasonable adjustments
"As his commitments have not been agreed his payments have been on hold which means his rent account is now in arrears and the Income Team are looking to serve a Notice Of Seeking Possession.I believe it is entirely possible that the claimant commitment can be accepted in writing and this is confirmed within paragraph J1007 of the ADM which you can find here:
"J1007 The methods by which a claimant commitment can be accepted by a person is set out in regulations as 1. electronically or2. by telephone or 3. in writing1 . The Secretary of State can specify which of these methods are to be used by a person to accept their claimant commitment. UC Regs, reg 15(4)”
Is it possible you can contact whoever is requesting the f2f or video consultation and advise them accordinglyMr feels his requests for reasonable adjustments due to his health issues are being ignored."
CB's 5 Sept 2025 response
- First, reasonable adjustments requires CB to help me, access the DWP.
- Second, the Judge, she misquotes.
- Third, whatever she says next means CCC may make seek possession
- Fourth, reasonable adjustments must relived the problem.
"From: JCP Customer Service Leader CB@DWP.GOV.UKSent: 05 September 2025 13:13To: SB@cambridge.gov.ukSubject: RE: RyanHi S,Thank you for your email,Whilst I appreciate you highlighting the ADM and requesting reasonable adjustments to undertake a commitment, a commitment cannot be considered until Mr RYAN undertakes the actions as explained in his Universal Credit account in relation to confirming the status of his self-employment.This is because Mr RYAN was a UC Migration customer due to being in receipt of Tax Credits due to self-employment. DWP have offered Mr RYAN a face to face, video or phone call to undertake the Gainfully self-employed appointment, I have also offered an alternative office undertakes the appointment, which are suitable reasonable adjustments for the appointment type.Please be aware it is not appropriate to undertake this appointment type in writing, as it an assessment of a customer self-employment status, as a result of an interactive interview between the claimant and the work coach. Mr RYAN chose to not attend the Gainfully self-employed appointment which was booked for him.Mr RYAN has been advised how he can declare a change of circumstances if he is no longer undertaking self-employment or receiving an income from his self-employment which will be considered and may negate the need for the Gainfully self-employed interview..A judge has agreed with DWP we have offered suitable reasonable adjustments to Mr RYAN which are not to his pleasing.Whilst it is an open legal case, Cambridge Jobcentre will continue to follow guidance and the advice of our Legal Team and Policy Teams.ThanksCB"
After this strong rhetorical counter-argument, CCC are confused. As intended.
Instead, of asking for clarification. then started proceedings on the 11 Sept 2025, and 17 Sept 2025 with a time to start proceedings 3 Nov 2025.
When I got hold of CB's email I thought that CB misrepresentation was the problem. I was wrong. Wrong to spent almost a month wasting energy on explaining to CCC that the statement was wrong. I even provided the court orders.
This all fell on deaf ears because CCC was being CCC.
The same CCC that takes 5 years to install a bathroom. The same CCC that deletes complaints. The same CCC that you need a solicitor to explain how the law works. The problem was the was the officer who signed the possession order visited me at home and tried to deliver a notice, on the 11 Sept 2025. Like myself DR is clearly dyslexic. And economical with the truth. I am grateful that I started recording on my phone then opened my door. DR greeted me and introduced himself by his first name only. I replied. He then asked me about the circumstances of the rent arrears - as if he was listening. However at the end of our discussion he was about to hand me a prewritten letter - as if he was not listening.
But I listed as DR defended the DWP for their action in my claim in 2025. To support he gave his background - as a 2020 DWP universal credit worker.
Standing on my doorstep was not a CCC official. It was the spokesperson for the DWP. Here is was he said:
[tk pending]
I received DR's statement, made on the day. 11 Sept 2025, in a GDPR reply. There is a big difference between what is on the recording. And what the council has in there records.
DR, in his statement decided to manufacture a person. A person that was not disabled. This is so he did not have to follow the possession proceedings for social landlords, "the protocol".
The protocol is a court rule that you must abide by before you start proceedings. Otherwise you can face court sanctions - fines - dismissing of the case and - extension of eviction notices. It is not optional. Especially for Disabidable, people, vulnerable people and those facing benefit arrears. This is mirrored in part in CCC tenancy policy.
What DR was trying to below, was to avoid following both CCC policy and the Protocol by erasing my disability with a visit. He was going to rely on his observation, perhaps in court to say why he did not follow the protocol.
DR critical mistake is I am not physically disabled. My disabilities are cognitive, social and mental. So when he is trying to fake an assessment of my disability, he is assessing the wrong type of disability.
So, it doesn't even matter if I can stand.
"stood for around 10-15 minutes unadded"
This is disgusting. DL is misrepresenting me being well, not asking for medical evidence, in order to send a possession claim.
Even though I told him about my health and that I was recording and that I would sue him for discrimination he still did the following:
DL wrote in CCC records that I was not disabled. (I have not edited the spelling mistakes):
"Mr answered the door. I explained I was there to speak about the rent account. He spoke about his problems with UC. I asked if he had tried to speak to his MP and he said the MP has refused to help him. He said that he had made his request for reasable ajustments to UC and Sarah. It was up to them to sort out his benifits. He said he had emailed the hight court about his case and had sued inderviduels involved in his case. I brought the conversation back about the rent account and why I was there. I was following are procedures. At this point he began to get angry and was swearing when speaking to me. I asked his not to and he said he had been recording me. He showed me the phone hidden on a stall in the bathroom under some papers. He said that I could not serve him with a notice. I explained that is was not a notice but a warning letter and I could go thorugh it with him. He kept saying I could send it recourded delivery or her would not except it. He was becoming more agrasive so I left and said I would post it to him. He closed the door. As I walked away down the passage he opened the door. I could not see him but he began talking/shouting like I was still in front of him. I could not hear what he was saying.
Notes - Mr did open the door to me apone my second time of knocking. He was very confedent when he was speaking to me and stood for around 10-15 minutes unadded. He looked very well kept and the property was clean and tidy."
I wrote to a letter before action on the 23 Oct, delivered it on the 23 th with a deadline 24th Oct 3pm to retract the statement and the possession notice. With pending NOSP claim 3 Nov, and one month of ignoring the evidence sent of my real disability, has enough notice.
But I heard nothing from DR.
CCC cc me on email application to court to strike out claim against G 25 Oct 2025
On the 25 October 2025 CCC legal copied me in on an application to my claim against one of their employees, G.
That application was hoping to strike out the claim against their employee was unarguable. Meaning that it was bound to fail. But this obviously was known before the claim was made.
Let me explain.
According to law, you cannot be made to sue someone. LexisNexis/ Practical Law:
"As a general rule, claimants are entitled to pursue which defendants they wish, and cannot be required to join defendants that they do not wish to sue (Smith v Michelmores Trust Corporation Ltd, applying Dollfuss Mieg v Bank of England). But this is subject to special cases for which different provision has been made by law, including by the rules of procedure, for example under CPR 64 (Smith v Michelmores Trust Corporation Ltd)..."
According to law, the person on the claim form is the person entitled to respond. And maybe their solicitor.
But CCC is not a defendant. G was. So why did CCC make the application.
And CCC cannot be G and CCC's solicitor. Because CCC retains the services for itself, not G. So why did CCC file an AOS.
See above waiting for 5 years for a disability bathroom, is one explanation. Just because they feel like it.
Why did I sue G
I was homeless. A NOSP makes you homeless or threatened with homelessness. And CCC has a duty to assess you. DR if he followed the CCC's policy and the protocol I should have been referred: Care assessment, Homelessness assessment, and to a third party. So I did.
G was a person who responded to my request. They wanted to assess me by phone!
No matter how much I explained, complained, provided medical evidence, made reasonable requests and quoted the Statutory guidance he was write:
(I note that I called ... and you did not pick up) words to that effect.
He was making a note. To set up a dismissal of my homeless request.
I made a note back.
I asked for the complaint number and the person who was going to contact me. I got no information. about this. So I began to feel intimidated.
Here was someone, who wanted to assess me on the phone, and he could not even handle complaints, follow the housing guidance, acknowledge reasonable adjustments. He was doing whatever he wanted.
He called me on the date I said not to call. Then I sent the claim and particulars the next day...
In response he gave me the link to complain.
Why did I report SN to the SRA
SN contacted me in relation to the claim against CCC and G. He said that he was a litigation lawyer and a solicitor representing CCC and G.
He is a Lawyer and a Solicitor.
He represents both CCC and G.
There is a claim against CCC and G.
One of those sentences is correct. All three of them are a problem between SN and the Solicitors Regulation Authority "SRA".
Let me explain.
Only yourself and a Solicitor is allowed to conduct litigation. You in your case. SN, sending an email on behalf of CCC in the claim against myself and G, was litigation. But he was not a registered solicitor.
So I reported SN to the SRA. I received a reply on the morning of the 24 Oct 2025.
Why should I make a second report to the SRA?
Instead of DR doing what I asked he did what he had done since 11 Sept 2025 to 24 Oct 2025, lie low and have CCC send unlawful applications.
I have likely paid my rent for the year, with the cost of the litigation. Imagine if CCC contacted the DWP and asked them to make reasonable adjustments for me in my UC claim. Maybe I could be safe and secure in my home, and CCC would have their rent. But...
In the afternoon of 24th Oct 2035 as 1630 I was copied in on an application to strike out the claim against G to a court. I was hoping that I would be able to respond by the
1630 and it being a friday are notable for court applications. No help. Courts close at 4:30pm. Psychological pressure of worrying the weekend about the order. The order is not likely to be processed.
In the application to my claim with G, not CCC - the same error of trying to say that CCC was a defendant (abuse of process).
The same argument that you cannot sue an employee. Threats of costs etc. But no proof of service of the letter they claimed to have sent me by the SN. SN if you remember is being investigated by the SRA,
I replied to the court, and copied in the SRA.
I then got an email from CCC legal wanting to negotiate.
A recap.
My rent to pay for my rent arrears and more are two £3000 claims of discrimination by CCC employees.
G refused to take a complaint, reasonable adjustments and follow the statutory code for homelessness.
DR came to my doorstep, defended the DWP, fabricated my wrong disability, ignored the CCC policy and ignored the possession protocol, in order to made the possession notice
These claims are worth more that £6000.
CCC has not responded officially to my letter before action for Judicial review, but has twice contacted me about claims they are not defendants in.
These three issues and more are worth more than my home:
- Defending discriminatory acts by its employees
- Repeatedly ignoring the statutory homeless process in 2019 and 2025.
- Failing to address significant disrepair in my flat, bathroom, and garden.
- Ignoring and deleting formal complaints.
- Using the legal system as a tool for harassment.
- Breaching the rules of natural justice.
There is no way that a court would let you make a possession claim, as this behaviour is not legitimate.
I have all weekend to document the way you have treated me since 2019.
Yes I have emailed the CEO of Cambridge.
No, I have not received an official answer to my letter before action for Judicial Review. See this Statement of facts and grounds.
CAMBRIDGE CITY COUNCIL: INCOME MANAGEMENT AND RENT ARREARS POLICY
1.6 The City Council also has a tenancy sustainment team who offer specialist help and advice for tenants with mental health issues...
1.8 City Homes will also consider, when taking possession action, the Housing Act 1996, the Human Rights Act 1998, the Equality Act 2010 and our duties under the Public Sector Equalities Duty within this Act, as well as any other relevant information or Acts, and will make assessments accordingly.
1.9 This policy relates to secure tenancies only, but will refer to other relevant policies in order to reflect a balanced and holistic approach to the collection and recovery of rent arrears across all tenure types. ...
4.0 PROCEDURE
4.1 City Homes have set comprehensive rent arrears recovery procedures and flowcharts to support the policy (Appendix 1), covering the process from early intervention to eviction. The procedures are reviewed on a regular basis to ensure they remain current and relevant.
4.2 The procedures provide detailed guidance for staff when dealing with rent arrears cases and comply with the Pre-Action Protocol for Possession Claims by Social Landlords (Appendix 2).
4.3 In line with our procedures all possession claims are entered onto the Possession Claims On Line (PCOL) website by staff after approval from the Income Manager.
4.4 Eviction requests are subject to rigorous checks, and a checklist completed, before approval is sought from the Strategic Director (Appendix 3).
Procedural Flow for Secure Tenancies
Week 1 (New Tenancies): Send New Tenant Letter (NEWT). If UC claimant, include info leaflet.
Week 3 (2 weeks in arrears): Send Invoice (LTR1). If UC claimant, send UC letter and leaflet.
Week 4 (3 weeks in arrears): Phone call, email, or text to chase debt. Contact support worker if applicable, or refer to rent advisor.
Week 6 (5 weeks in arrears): Raise and serve a Notice of Seeking Possession (NOSP) with a 3-month rent statement.
Week 7 (6 weeks in arrears): Make a formal referral to a support agency (with prior tenant consent).
Week 8 (7 weeks in arrears): Arrange a home/office visit to set up a formal payment arrangement (ARR). Refer to rent advisor if appropriate.
Week 10 (9 weeks in arrears): Send a pre-court warning letter (CAPL).
Week 12 (11 weeks in arrears): Enter court application (CAP), after checking pre-action protocol has been adhered to. Authorised paperwork is entered on the Possession Claims On Line (PCOL) system.
DWP Policy
"Delivering Equality for customers - Access to DWP services
About these instructions
1. All DWP staff have a legal duty to comply with the requirements of the Equality Act 2010. We have a legal duty not to discriminate against customers who are protected by the Equality Act.Therefore, staff must make sure they understand their responsibilities so that they know how to cognise customers who may need additional support to access DWP services; how to put the necessary support in place for customers and how to ensure this is consistently applied.2. “Customer” refers to any person or organisation that accesses our services.(customer, client, claimant, citizen, employer, partner)3. This guidance is to inform and raise awareness of:
- The Equality Act 2010;
- How the Equality Act affects DWP;
- The Equality Actions you must take when dealing with customers who require additional support;
- How to provide a reasonable adjustment
- Equality Act Accessibility checklist
4. Remember, you may have to do something different to enable a customer toreceive equal access to benefits and services."
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