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Reparations Schedule & Proposed Apportionment

page · Updated 2026-10-20T14:38:14 · Original source

Page ID: 5475 · Title: Reparations Schedule & Proposed Apportionment · Evidence status: FAMILY’S PROPOSAL / ESTIMATE — liability unproven · Version: 1.0.0 · Editing Protocol

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ConstraintEntry
StatusThis is the family’s proposal, not a finding. No party has admitted liability and no court, ombudsman or reviewer has found any party liable. Every role below without an evidence ID is SOURCE PENDING. Research support, not legal advice.
Parent page5298 — Damages, Losses & Costs Quantification. Figures here are taken from 5298 and are not recalculated. 5298 holds the methods and sources.
FiguresEvery £ figure is an ESTIMATE with its method stated. Where there is no basis, the row says “valuation needed” and names the method. Today’s £.
Totals5298’s routes B1, B2 and C are alternatives. The total below is route C (fraud proven), which is the widest. It is not added to B1 or B2.

1. Heads of loss

#HeadBasis / methodLow (£)Mid (£)High (£)Evidence held / neededStatus
1Land: Parcel A (≈10 acres; house and garden, woodland, south-east ground VG41)Residual land share of developed value (central/high) or existing-use value (low). 5298 Head 1£621,000£2,809,000£4,096,000Held: planning record 92/00671/RES [EV-0127], site layout [EV-0135], HMLR Price Paid. Needed: plan areas of the three parts; RICS valuation; title re-established (1987 judgment [EV-0080] set aside, or register rectified).Family’s claim · ESTIMATE · CONDITIONAL
1bLand: Parcel B (≈9 acres)Valuation needed (method: plan area × agricultural £/acre, Savills 2025 range on 5298). Not quantified: [SOURCE PENDING] Bute retained it and it was “given up later”.valuation neededvaluation neededvaluation neededHeld: 1939 plan [EV-0023] (a monthly grazing let, not proof of a tenancy of Parcel B). Needed: any title or tenancy document for Parcel B.Family’s claim
1cLand: woodland and wider Cedwyn estate parcelsValuation needed (method: parcel-by-parcel title check, then £/acre for woodland). The Forest of Cardiff accounts show a Leckwith Road land sale of £20,000 to Jun 2006 [EV-0217].valuation neededvaluation neededvaluation neededNeeded: titles by parcel (e.g. WA735527), and the family’s parcel list.Family’s claim
2The farmhouse / home (Tŷ Mawr), demolished Dec 1988Its site value is already inside Head 1 (not counted twice). Any separate value as a historic building: valuation needed (method: RICS building surveyor; reinstatement cost of a comparable historic farmhouse, or loss of amenity).in Head 1in Head 1in Head 1Held: press reports of demolition [EV-0108], [EV-0111]; Cadw 29 Jul 1988 photographs (sought, ATISN 27589). Needed: photographs, measured description, any listing file.Family’s claim · CONDITIONAL
3Contents and belongingsValuation needed (method: itemised inventory × replacement value; or second-hand value at Nov–Dec 1988, indexed).valuation neededvaluation neededvaluation neededNeeded: an inventory from the family (what was in the house and outbuildings on 29/30 Nov 1988; what was recovered; what was lost or destroyed).Family’s claim
4Heirlooms and artefacts (“treasures looted”)Valuation needed (method: auction-house or museum valuation per identified item). Alternative remedy for an identified item: return (delivery up) rather than money.valuation neededvaluation neededvaluation neededHeld: Museum Wales FOI 2026-024 / 032 / 036 on c.1880 medieval ironwork from the farm. Needed: a list of each item, where it is now, and how the family owned it.Family’s claim
5Loss of heritage, history and archiveNot usually compensable in money. Proposed remedies in kind: return or copying of records, correction of public records (HER/SMR), acknowledgement, and interpretation (see Project P4, replica museum). Cost of remedies in kind: valuation needed (method: quotes).valuation neededvaluation neededvaluation neededHeld: HER GGAT02038s (SMR card Mar 1989 “destroyed by owners”). Needed: list of lost records and objects.Family’s claim
6Loss of use and mesne profits, Dec 1988 – Oct 2026Market rent backcast by Wales HPI. 5298 line 2b (full period, deceit measure). Alternatives on 5298: v BP Dec 1988–Nov 1993 only £15,100 / £16,600 / £20,800 (2a); last 6 years only £89,700 / £98,900 / £123,600 (2c). Woodland and VG41 ground since 1955: valuation needed (method: grazing or amenity rent).£308,800£340,300£425,400Held: ONS rents; UK HPI Wales; dispossession 29/30 Nov 1988 [EV-0106]. Needed: title re-established.Family’s claim · ESTIMATE · CONDITIONAL
6iInterest on loss of use5298 line 4c: Bank Rate / Bank Rate +1% / 8% simple.£99,900£156,100£459,400Basis on 5298 (s.35A Senior Courts Act 1981).ESTIMATE · CONDITIONAL
7Distress and injury to feelings (5 persons)Vento bands by analogy: middle-band floor / midpoint / top per person × 5. 5298 Head 5£63,000£125,800£188,500Needed: list of living claimants and estates. Note: the 1987 judgment records “no grant of representation to the estate of Mrs Buckler has so far been obtained” (as of 1987), and that Mr Buckler junior “must claim through Mrs Buckler’s estate if he has any claim”.ESTIMATE · CONDITIONAL
8Personal injury: nan’s leg amputation (Mrs Mary Buckler, c. 1955)Verified (court record): BP Properties Ltd v Buckler [1987] EWCA Civ 2 records that when the 1955 possession order was enforced on 4 July 1955, Mrs Mary Buckler (daughter of Mr Williams, mother of Mr Buckler junior) “had recently come out of hospital after having had a leg amputated and was objecting very strongly to leaving the farmhouse. There was even, apparently, a fear that she might attempt suicide.” She died in March 1983. So the amputation was about 1955, during the first eviction dispute. SOURCE PENDING: the amputation is attributed to the stress of the dispute. Causation is unproven. Valuation needed (method: medical records, then a medical expert on causation, then the Judicial College Guidelines bracket for the level of amputation).valuation neededvaluation neededvaluation neededHeld: 1987 judgment (who, and that it was shortly before 4 July 1955). Needed: exact date and hospital; medical records; any GP or hospital note linking it to stress. A claim would be through her estate (see row 7 and the estates note).SOURCE PENDING · causation unproven
8bPersonal injury: William Buckler, taken to Llandough Hospital after the eviction, Nov 19885298 line 5b. Valuation needed (method: medical records, then Judicial College Guidelines).———Needed: medical records (deceased-records request to Cardiff & Vale UHB, 20 Aug 2026).PENDING
9Bereavement: loss of family members (nan and dad)SOURCE PENDING: the dispute contributed to the deaths of nan and dad. Causation is unproven. Note: the statutory bereavement award (Fatal Accidents Act 1976 s.1A) is limited to a spouse, civil partner or long-term cohabitant, or the parents of a child under 18, so it does not cover a grandson or adult son. Valuation needed (method: any claim would be part of distress (Head 7) or the estates’ own claims, after medical causation evidence).valuation neededvaluation neededvaluation neededNeeded: death certificates. Records conflict: Mary Doreen (Nancy) Williams (nan) is recorded in a 2026 records request as dying in 1983; William Buckler’s death is recorded as 1990, 1991 and 15 May 1992 in different places.SOURCE PENDING · causation unproven
10Human rights: A1P1 (property) and Article 8 (home)Valuation needed (method: “just satisfaction”, usually modest and linked to the domestic heads above). Only against public authorities.valuation neededvaluation neededvaluation neededSee limitation note: the Human Rights Act 1998 does not apply to events before 2 Oct 2000.Family’s claim
11Aggravated and exemplary damagesOnly if fraud or oppressive conduct is proven. Court’s discretion; exemplary category 2 is measured against the defendant’s profit (developed value £11,039,000 on 5298 line 1a, less land and build cost, not held). 5298 4d–e.TBCTBCTBCNeeded: fraud or concealment proven to the civil standard.CONDITIONAL
12Ongoing costs of pursuit (Sion’s time as litigant in person)£24/h (CPR 46.5, no proven loss) × 5 / 10 / 20 h a week × 54 weeks. 5298 line 8a. Running ledger in section 2.£6,480£12,960£25,920Needed: Sion’s hours log; receipts for disbursements; a costs order.ESTIMATE (hours TBC)
Total (route C: fraud proven)HeadsLowMidHighNote
Quantified so far1 + 6 + 6i + 7 + 12£1,099,480£3,443,760£5,195,420Matches 5298 route C (rounded there to £1,099,000 / £3,444,000 / £5,196,000). ESTIMATE · CONDITIONAL.
Not yet valued1b, 1c, 2 (separate value), 3, 4, 5, 8, 8b, 9, 10, 11———Each needs facts or a valuation first (see Gaps).
Alternative: register mistake proven, no fraud (route B2)5298 Head 3 + 8£171,600£759,600£1,376,000HMLR indemnity route. An alternative to route C, not an addition.

2. Ongoing costs of pursuit — running ledger

Sion’s own time is claimable only under a costs order (CPR 46.5) at £24 an hour unless he proves a higher financial loss. Disbursements need receipts. Work done for Sion by his assistant is not Sion’s time; only his own hours instructing and reviewing count. Add one row per session or payment. Figures are only entered where they are recorded.

DateItemHours£ (hours × £24, or receipt)Receipts / evidence
5 Oct 2025 – 18 Oct 2026Sion’s case work, sustained period (54 weeks)TBC (ESTIMATE 270 / 540 / 1,080 h)£6,480 / £12,960 / £25,920 (ESTIMATE)5298 line 8a
23 Mar 2016 – 18 Oct 2026Composing case emails (time proxy: 488 sent emails at 20 words/min). A floor, and overlaps the row above; not added.≈203 h (ESTIMATE)≈£4,870 (ESTIMATE)Gmail read-only count, 18 Oct 2026 (I-015)
16 Aug 2016 – 4 Oct 2025Earlier case workTBCTBC5298 line 8c
to 18 Oct 2026Disbursements paid—£0Highlight Report w/e 18 Oct 2026: £0 spent
18–19 Oct 2026Review and consolidation of 41 draft records requests and complaint letters (one email per organisation)TBC (Sion to log)TBCGmail drafts, 19 Oct 2026
18–19 Oct 2026HM Land Registry subject access / EIR request framing, incl. the “Mrs Buckler” identity questionsTBC (Sion to log)TBCGmail draft to HMLR, 19 Oct 2026
18–19 Oct 2026Case calendar for 19–25 Oct and the 22 Oct Llandough Community Council meetingTBC (Sion to log)TBCCalendar
18–19 Oct 2026Wiki: damages page, PRINCE2 pages, correspondence pages, this scheduleTBC (Sion to log)TBCMaster Change Log 3923
Archive visits (dates TBC)Glamorgan Archives / Leckwith visits (3), incl. travel and copyingTBCTBC (travel and copy receipts)Visit notes
PlannedHMLR official copies, form OC2, C-01 to C-06 (only for papers not disclosed under the SAR/EIR)—£11 each (published fee); not orderedProject Plan — cost table
PlannedGlamorgan Archives DB/E/1–2 plan 19 and terrier (T18)—£17 (quoted); not orderedProject Plan — cost table

3. Proposed apportionment between the parties

Caveat: this is the family’s proposal, not a finding. Liability is unproven against every party named. The shares are a starting point for negotiation, weighted by each party’s asserted part in the chain of loss: who acted, who profited, and who could have prevented it. Statutory routes do not share loss this way: for example, an HMLR indemnity would be paid by HMLR in full, and HMLR could then seek to recover it from a party whose fraud caused the loss (LRA 2002 Sch 8 para 10). Illustrations use the route C mid total (£3,443,760).

PartyAsserted role (SOURCE PENDING unless an evidence ID is cited)HeadsProposed shareRationaleIllustration at mid (£)Legal route
BP plc (successor to BP Properties Ltd / BP Pension Trust)Applied for first registration of WA231076 (30 Nov 1982) and WA240304 (23 Feb 1983); brought the possession claim (judgment 1987 [EV-0080]); evicted the family 29/30 Nov 1988 and demolished the house Dec 1988; sold to Ideal Homes Dec 1993. Allegation under investigation: the registration statements were false and the occupiers were not properly identified or notified.1, 2, 3, 4, 5, 6, 6i, 7, 8, 8b, 9, 11, 1260%Primary actor and the party that profited from the land.≈£2,066,000Letter before claim (Practice Direction – Pre-Action Conduct); civil claim in deceit, trespass and conversion; application to set aside the 1987 judgment for fraud (Takhar v Gracefield [2019] UKSC 13).
HM Land RegistryRegistered BP’s titles in 1982–83 and amalgamated them on 2 Feb 1987. Allegation under investigation: a registration mistake, in that an occupied farm was registered without the occupiers being identified or notified, and the file refers to a “Mrs Buckler” (identity disputed).1, 6, 12 (indemnity route: Head 3 on 5298)20%Public register; the State guarantee of title is the statutory backstop for a register mistake.≈£689,000HMLR complaint (stages 1–2 done); Independent Complaints Reviewer (ICR/090/26); indemnity claim under LRA 2002 Sch 8, then the court (Sch 8 para 7); rectification under Sch 4.
Vale of Glamorgan CouncilPlanning permissions for housing on the site (89/01396/OUT; 92/00671/RES [EV-0124], [EV-0127]); 1983 conservation interest; reported 1989 legal action against BP [EV-0117]; [SOURCE PENDING] that it went nowhere; delays in disclosing records (FOI 00210772).2, 5, 7, 125%Planning and conservation authority with power to intervene.≈£172,000Corporate complaint, then the Public Services Ombudsman for Wales; ICO for FOI (s.50 FOIA); civil claim (family’s claim).
Welsh Government / CadwListing consideration in 1988 (Cadw photographs 29 Jul 1988, sought); the 1988 listing file is lost; the house was demolished unlisted.2, 4, 5, 105%Heritage authority; record lost.≈£172,000Welsh Government complaints (stage one open, ticket #628635887), then the Public Services Ombudsman for Wales; FOI/EIR (ATISN 27589, 26-0009, 26-0010).
South Wales PolicePresent at or connected with the Nov–Dec 1988 eviction and demolition (SOURCE PENDING); a press report of hospital assault charges [EV-0101].7, 8b, 105%Public authority at the eviction; reported conduct towards the family.≈£172,000Complaint to SWP Professional Standards, then the IOPC (a complaint about events over 12 years old needs a good reason for the delay); SAR (20 Aug 2026) and FOI 1264/26 for records.
Solicitors involvedLoosemores, Cardiff (the family’s solicitors in 1986–87): [SOURCE PENDING] the defence was mishandled. Other firms named in the 2026 preservation notices (Blake Morgan, Darwin Gray, Linklaters, Landmark Chambers): records holders; no allegation recorded on the wiki.1, 6, 123%Professional negligence by the family’s own advisers (family’s claim).≈£103,000The firm’s complaints procedure (or its successor’s), then the Legal Ombudsman; SRA for conduct; civil claim in professional negligence (subject to the 15-year longstop, see Limitation).
Persimmon Homes / Ideal Homes Wales successorsBought from BP on 3 Dec 1993 and built 20 houses (Church View Close); later sold the woodland (SOURCE PENDING).1, 6 (Dec 1993 – 1995), 42%Developer that took the benefit of the site.≈£69,000Letter before claim. Note: an innocent purchaser for value is protected (Limitation Act 1980 s.32(3)).
Others in the draftsHeneb (ex-GGAT): HER record “destroyed by owners” (complaint 27 Sep 2026). Museum Wales: c.1880 ironwork. Forest of Cardiff: woodland title and the £20,000 land sale. Cardiff County Court / MoJ: records only (judicial acts are immune).4, 50% (remedies in kind)Record correction, return or copying, acknowledgement.—Complaints procedures; FOI; requests for return or copies.

Shares total 100%. Remedies in kind (records, return of items, acknowledgement) are proposed alongside money and do not reduce any share.

4. Opportunity to remedy

Each party is to be given a fair chance to put things right before any claim. Proposed standard: a letter before claim giving a reasonable time to respond. The Practice Direction on Pre-Action Conduct treats 14 days as reasonable in a simple case and up to 3 months in a very complex one; this case is complex, so 3 months is proposed. Dates below are from the correspondence pages and the draft emails of 19 Oct 2026. “Drafted” means not yet sent.

PartyComplaint routeSent / draftedResponse deadlineStatus
BP plcPreservation notice; records enquiry to BP Archive; letter before claimPreservation notice sent 28 Sep 2026 (BP correspondence). Records enquiry drafted 19 Oct 2026. Letter before claim: not yet drafted (plan task P0-LIT-05, due 23 Oct 2026).Records enquiry: 16 Nov 2026 (in draft). Letter before claim: 3 months from sending (proposed).No remedy offered. Letter before claim to be drafted.
HM Land RegistryComplaint stages 1–2; Independent Complaints Reviewer; SAR/EIR; internal applicationStage 1 decision 19 Apr 2026 [EV-0149]; stage 2 acknowledged 21 Apr [EV-0150], decided 25 May 2026 [EV-0153]; ICR referral sent 27 Sep 2026 (ICR/090/26); internal application Z084NQV opened 10 Oct 2026; SAR/EIR email and ICR follow-up drafted 19 Oct 2026.SAR due 28 Oct 2026. ICR follow-up: 6 Nov 2026 (in draft). Full ICR complaint: target 13 Nov, outer date about 25 Nov 2026. SAR/EIR email: 16 Nov 2026 (in draft).Complaint not upheld at stages 1 and 2. ICR pending. Indemnity claim not yet made.
Vale of Glamorgan CouncilCorporate complaint; FOI/EIR internal review; then Ombudsman / ICOComplaint to the Monitoring Officer about the ward councillor sent 27 Jul 2026; FOI 00210772 internal review overdue as of 6 Oct, chased 7 Oct 2026; consolidated FOI/EIR email drafted 19 Oct 2026.Consolidated email: 16 Nov 2026 (in draft).Internal review overdue. Ombudsman and ICO steps on hold.
Welsh Government / CadwWelsh Government complaints, stage one; FOI/EIRStage-one complaint 17 Sep 2026 (ticket #628635887), supplement 22 Sep 2026; Complaints Manager replied 30 Sep 2026 that officials would respond; consolidated FOI/EIR email drafted 19 Oct 2026.ATISN 27589: 26 Oct 2026. ATISN 26-0010: 6 Nov 2026. Consolidated email: 16 Nov 2026 (in draft). Chase if no stage-one outcome: 20 Oct 2026 (plan T08).Awaiting the stage-one response.
South Wales PoliceSAR; FOI; conduct complaint (not yet made)SAR sent 20 Aug 2026 (clock paused: clarification asked 30 Sep 2026); FOI 1264/26 clarification acknowledged 16 Oct 2026; FOI email drafted 19 Oct 2026.FOI 1264/26: 9 Nov 2026.No conduct complaint lodged. SAR paused until Sion clarifies.
Solicitors involvedPreservation notices; firm complaints procedure; Legal Ombudsman; SRAPreservation notices sent 28 Sep 2026 (Linklaters replied 29 Sep; Landmark Chambers replied; Blake Morgan and Darwin Gray did not reply). Follow-ups and SRA / Law Society / Bar Council records requests drafted 19 Oct 2026. No complaint to Loosemores’ successor yet.Follow-ups: 16 Nov 2026 (in draft).Records stage only.
Persimmon / Ideal Homes successorsPreservation letter; records request; letter before claimPreservation letter sent 27 Sep 2026 (automatic replies only, Persimmon correspondence); records request drafted 19 Oct 2026 (address may bounce).Records request: 16 Nov 2026 (in draft).No substantive reply.
Heneb (ex-GGAT)Formal complaintLodged 27 Sep 2026; acknowledged 29 Sep 2026; follow-up drafted 19 Oct 2026.Outcome aim: 3 Nov 2026 (five weeks).Awaiting outcome.
OmbudsmenPHSO; Public Services Ombudsman for WalesPHSO complaint 25 Jun 2026; reply 16 Jul 2026 (C-2205633) pointed to the Welsh Ombudsman. PSOW emails Feb–May 2026; PSOW asks for its online form.—No PSOW complaint form filed. It comes after each body’s own process.

5. Limitation and what must be proven

ClaimTime limitWhat would need proving
Recovering the landLimitation Act 1980 s.15: 12 years; s.17 extinguishes title after that.s.32(1)(a)/(b): time runs from when fraud or deliberate concealment was discovered, or could with reasonable diligence have been discovered. The claimant must prove it. s.32(3): no recovery of the property or its value from an innocent purchaser for value (current homeowners).
Setting aside the 1987 judgmentCourt’s power to set aside a judgment obtained by fraud.Takhar v Gracefield [2019] UKSC 13: no need to show the fraud could not have been found earlier, but the new evidence must show conscious and deliberate dishonesty that materially caused the judgment. Until set aside, the 1987 judgment [EV-0080] stands against the family.
Deceit, trespass, negligence (money claims)s.2: 6 years from the damage.Postponed only under s.32. For negligence, s.14A gives 3 years from knowledge, with a 15-year longstop (s.14B) that s.32 deliberate concealment can override (s.32(5)).
Personal injurys.11: 3 years from injury or knowledge.s.33: the court may disapply the time limit. Causation needs medical evidence.
Goods (contents, heirlooms)s.3: 6 years for conversion.s.4: no time limit against the thief for stolen goods, and the owner’s title is not extinguished. Each item must be identified and shown to belong to the family.
HMLR indemnityLRA 2002 Sch 8 para 8: 6 years from when the claimant knew, or ought to have known, of the claim.Needs a register mistake proven, and the loss caused by it. Indemnity is reduced for the claimant’s own lack of care (Sch 8 para 5). 1983 law (Land Registration Act 1925) applies to the mistake: solicitor to confirm the transition.
Human rightsHuman Rights Act 1998 s.7(5): 1 year.The Act does not apply to events before 2 Oct 2000. A claim would need a continuing or later act by a public authority (e.g. a decision in 2025–26).
Claims of nan and dadTheir claims survive for the benefit of their estates (Law Reform (Miscellaneous Provisions) Act 1934 s.1).Needs a grant of probate or letters of administration, and the death certificates. The same time limits apply to the estates. Verified: BP Properties Ltd v Buckler [1987] EWCA Civ 2 records that “no grant of representation to the estate of Mrs Buckler has so far been obtained” (as of 1987).

6. Gaps: facts only the family can supply

Fact neededUsed in head
Nan’s amputation: the exact date, the hospital, and any medical records (who and roughly when are now verified: Mrs Mary Buckler, shortly before 4 July 1955, per the 1987 judgment)8, 9
Death certificates for nan and dad (nan: March 1983, per the 1987 judgment; dad: records conflict, 1990, 1991 or 15 May 1992)9, limitation, estates
Grant of probate or letters of administration for each estate (executor named in the will). For nan, the 1987 judgment records no grant had been obtained as of 1987; any later grant?all estate claims
Inventory of belongings: what was in the house on 29/30 Nov 1988, what was recovered, what was lost3
Inventory of heirlooms and artefacts: each item, where it is now, how the family owned it4
Parcel list: areas of the three parts of Parcel A; any Parcel B and woodland documents1, 1b, 1c
Sion’s hours log and receipts (from 16 Aug 2016)12
Living claimants (who suffered distress) and their dates7
Any evidence of the 1969 name change (divorce decree or deed poll)HMLR “Mrs Buckler” identity point

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